Introduction

This paper looks at the drivers, and highlights the different approaches taken throughout Europe, to implement the EECC directives in support of end users switching communications provider and porting their number(s).

Background 

Once upon a time, communications providers tended to be a monopoly provider and vertically integrated - essentially a typical residential customer had one option for communications services (typically a telephony service). The 1980’s saw the privatisation of many national telecom providers and the 1990’s ushered in an ecosystem of multiple telecom retailers providing services via wholesalers.  While a customer could shop around, the retailers typically offered competing services over the same infrastructure - all used the same pair of wires going into the premises. Around the same time, cable TV distribution networks using coaxial cable appeared in parallel in certain urban areas.

The mid 90’s saw the advent of broadband over twisted-pair copper with each technology offering improvements in throughput: first ADSL (1-12Mbps), then FTTC/VDSL (10-100Mbps). Coax became HFC and it too offered broadband capability (typically 30Mbps-500Mbps). In some countries, fibre in the form of FTTH/FTTP (30Mbps - 1Gbps) was deployed as copper replacement by the incumbents in selected areas. In other countries, alternative network providers (Altnets) rolled out high capacity networks: point to point wireless (2Mbps-100Mbps) or FTTH/FTTP (30Mbps - 1Gbps) in areas that were neglected by the incumbents or simply made economic sense.

Changing retail provider (e.g. moving from Retailer A to Retailer B) where both rely on the same infrastructure more or less took care of itself. The wholesaler simply lets the losing provider know that their customer has transferred elsewhere and that they are no longer billing them for the service - the retailer should now stop billing that customer for service.

Traditionally, moving from one infrastructure provider to a service based on another was a very rare event - you moved to a cable broadband network (>100Mbps) when the telephony-based network could only give you 6Mbps and you stayed. You moved to a wireless Altnet because they were the only option other than satellite and stayed.

With the deployment across Europe of Alternative networks, most being fibre based, the possibility of switching communications provider (including the underlying access network provider) is becoming more common.

The European Electronic Communications Code (Directive (EU) 2018/1972) revision of the EU regulatory framework for the telecommunications sector was adopted by the European Parliament in December 2018 and consolidated and reformed the existing regulation framework.

For the purposes of this paper, we’re focusing on Article 106, Provider switching and number portability. The article’s principles address this very issue of switching communications providers including switching the underlying access network provider:

• In the case of switching between providers of internet access services, the providers shall provide the end user with adequate information before and during the switching process and ensure continuity of the internet access service, unless technically not feasible. 
• The receiving provider shall lead the switching and porting processes.
• The transferring (or losing) provider shall continue to provide its internet access service on the same terms until the receiving provider activates its internet access service. 
• Both the receiving and transferring providers shall cooperate in good faith.
• Loss of service during the switching process shall not exceed one working day. 
• The end-users’ contracts with the transferring provider shall be terminated automatically upon conclusion of the switching process. 
• National regulatory authorities may establish the details of the switching and porting processes, … shall ensure the efficiency and simplicity of the switching process for the end-user … take appropriate measures ensuring that end-users are adequately informed and protected throughout the switching and porting processes …

Member states were expected to adapt their telecommunications regulations by 2020 in accordance with the directive, commonly referred to as the EECC.

What’s interesting is the variety of ways in which this has been or is being achieved. The following examples describe implementations in three countries, from an ambitious fully automated and technically complex approach (with onerous performance SLAs) in the UK, to a largely manual email-based approach in Denmark.  

UK

While no longer a member of the EU, the national regulator, Ofcom, is still driving compliance with the EECC.  In February 2021, the Office of Communications (Ofcom) consulted on “proposals for a new switching process for residential landline and broadband customers”. In September 2021, Ofcom published their “final decisions on these changes, including requirement for a new ‘One Touch Switch (OTS)’ process where landline and broadband customers will only need to contact their new provider to switch.

The UK market is large, with ~300 retail providers of residential broadband and voice services.  Another ~3000 providers provide similar services to the business market.  Approximately 29 million fixed connections exist at the end of 2023. The dominant player at an access-network layer is BT/Openreach. Other access networks with national presence include Cityfibre and Nexfibre (VirginMedia/O2 venture), Altnets in total cover approximately 35% of the UK.  ThinkBroadband tracks the footprint of ~110 Altnets. Naturally there are areas where overbuild has taken place, the extreme case being the town of Braintree, where five different gigabit-capable Fibre-to-the-Premises (FTTP) based broadband ISP networks have overbuilt each other. While this is extreme, choice of high capacity services networks is becoming relatively common, putting pressure on the industry to support for One Touch Switching.

The (residential) OTS industry process was substantially agreed by August 2022 and finalised in August 2023. The approach taken can be characterised as:

• A federated queryable database of service inventory (each provider hosting their own data).
• Receiving/gaining providers can match/validate customer address and service data at the transferring/ losing provider.
• A special purpose company, TOTSCo, has been created to build and manage a centralised Hub for the exchange of OTS-related messages between gaining and losing providers.
• The Hub is API driven (and does not include a portal for smaller providers with tiny switching volumes).
• The overall process comprises a match request, i.e. validation of customer details and their existing services with the losing provider, ordering/confirming intention to switch selected services and then triggering the cease of existing service with the losing provider.  
• A 60-second SLA is in place for the losing provider to communicate the results of the match request back to the gaining provider and equally importantly, to communicate the implications of switching to the end customer.
• In order to achieve this, all retail providers, regardless of size, must make their customer/service inventory available to be matched on a 24x7 basis.

The requirement to be available 24x7, the relative complexity of the switching lifecycle and the matching requirements have all contributed to the evolution of an ecosystem of ~10 Managed Access Providers (MAPs) who can assist the communications providers in achieving OTS compliance. 

While the solution is set to go live in September ‘24, approximately 140 providers have on-boarded to the TOTSCo OTS Hub, with a smaller number having completed end-to-end testing of the process and associated software and engaged in live trials.

For residential services, it is implicitly understood that the gaining provider has authorisation from the end customer to act on their behalf; however for business, reference to a “letter of authority” is supported. The introduction of GPLB, the equivalent of OTS for business customers is expected to follow quickly in the footsteps of OTS.  

Denmark

Denmark is a mature market with > 70% of homes being passed by FTTP networks.  Additionally, 98% of homes have 5G coverage. In all respects, Denmark is a modern, progressive country. This makes it somewhat surprising to see that Denmark introduced an email-based solution to handle notifications of inter-operator transfers in January 2023.

It includes an explicit reference to a grant of “power of attorney” to the gaining/receiving provider to act on the customer’s behalf and indeed an option to indicate to the losing/transferring provider to NOT contact the customer with marketing information.

The process is for each provider to support a named email address for receipt of incoming transfer orders, with the receiving provider starting the process by sending an email to the losing provider.

Email templates are defined for a total of 9 message types, with guidance on the content of the subject line. The initial transfer email must include the power of attorney notice as a PDF/JPG attachment. The overall lifecycle of the switch order is defined.

Given the nature of the chosen solution, SLAs are measured in days, rather than seconds.  Currently, ~25 providers are supporting this process. Interestingly, both gainer and loser must charge on the transfer day and the process covers both residential and business communications services and also transfers on the same infrastructure and to a new access network.

Ireland

The Irish market is currently characterised by 3 large wholesale fixed line providers, a large cable operator (currently retail only), and ~30 primarily-wireless broadband providers. 

All three wholesale networks support spontaneous loss notifications to retail providers when a customer moves from one to the other, so mechanisms already existed to support transfers from one retailer to another on the same infrastructure provider.  Historically, there was little overlap in footprint in FTTH and HFC networks. However this has changed.

With the advent of customer choice now between fibre networks and the HFC networks, and options to move from ADSL or VDSL with the incumbent to an FTTH-based network, a mechanism has been introduced to ensure that, for switching broadband service from one infrastructure provider to another, the receiving/gaining provider can inform the transferring/losing provider to cease service. It is implicitly understood that the gaining provider has authorisation from the end customer to act on their behalf.

The introduction of this is greatly facilitated by the fact that all residential premises in the country are identified by a unique code called Eircode which is commonly known and regularly used by the resident. For fibre, all 3 providers have 100% Eircoded data enabling correct identification of existing and new service delivery points.

The solution is based on an extension of the pre-existing number porting process with a central system handling transfers. While the process is only intended to cover the inter-access-network switching process where the gaining provider can trigger the cease of existing service, in practice, it is still the norm that the end customer takes responsibility for informing the losing/transferring providers to cease service. The most popular switching-advisory websites still inform the user that they must take responsibility for informing the losing provider to cease service.

Summary

The inter-provider communications mechanisms used to give effect to the European Electronic Communications Code (Directive (EU) 2018/1972) are not always publicised. It is interesting to see the variety of approaches used to enable a receiving-provider-led approach to transfer of provider and their relative complexity or lack thereof.

We’ve looked at the mainly manual approach taken in Denmark. It may be leisurely, but has a low cost for small providers to participate.

The Irish solution only addresses a small part of the overall switching volume - it is open to automation although the volumes may not justify this.

The UK solution is the most ambitious in scope, resulting in a distributed searchable service inventory of the national residential service footprint. All switches (even from one retail brand to another within a provider) must follow the OTS process. The SLAs are onerous. The requirement to interact with and respond via API-only to a central hub, with no portal support makes it expensive for smaller retail communications providers to comply. This complexity has created an opportunity for 3rd party service and solution providers, the ‘MAPs’, to support UK retail providers in achieving OTS compliance. Sonalake’s pivOTS is one such solution, and has already been deployed with several providers. Most recently (June ’24), one of our large ISP clients has become the first CSP outside of the ‘big 4’ to complete the final hurdle (PIT - production implementation testing) and has also carried out staff trials with other CSPs (switching live services). For more information see sonalake.com or pivots.uk.

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1 Altnet report 2024

2  Broadband map

3 Full Fibre Networks overbuilding

A previous study by Point Topic predicted that 75% of the UK would have a choice of three gigabit-capable broadband networks by 2030 here.

4 One Touch Switch Industry Process

5 Process technical documents

6 See OTS - build-in or buy? where the merits of the different types of MAPs are discussed. Sonalake is one such MAP, providing its pivOTS solution to the UK market pivots.uk

7 The Gaining Provider-Led Business process

8 Skift af bredbåndsudbyder

Nye regler og brancheaftale gør det nemmere at skifte bredbåndsselskab

9 Standardiseret protokol for udveksling af data mellem MU og AU i elektronisk format

10 There are edge cases where this is not so, but these can be regarded as data issues.