One year since Ofcom General Condition 22 came into force

Wednesday 13 February 2008 13:31:19 by Andrew Ferguson

It was one year ago on Valentine's Day 2007 that the Ofcom General Condition 22 came into force. GC22 lays out the way migrations between broadband providers should happen.

It should be pointed that the Migration Authorisation Code (MAC) process itself has existed a lot longer than this, but the changes last year made the issuing of MAC codes compulsory for IPstream, Datastream and shared LLU (SMPF) connections. Fully unbundled connections as used by Talk Talk and to a lesser extent Tiscali are not part of the process since at the time the processes were not fully developed.

At the time the rules for migration were created the bundling of broadband with other services was still fairly new, but now it is a large complex market. This has been noted by Ofcom who commissioned a study by Deloitte looking at the creation of a single switching process encompassing a wider range of services than just broadband. The danger with any new processes is that if too much power is given to the gaining provider, "slamming" (the process of mis-selling where a customer has not given express consent) becomes easier, either by genuine mistake or sales people chasing monthly targets.

The area causing the most confusion is that of unbundled (LLU) lines as there are two types of unbundled services. A "fully unbundled" (MPF) service is where the telephone line and broadband both connect to the providers own hardware whilst "shared" (SMPF - sometimes called partially unbundled) is where only the broadband element is unbundled.

Moving between a shared LLU provider and IPStream / Datastream connections can be done with a MAC but may incur an ADSL activation charge from the new ISP. The background process is called 'Provide with MAC' and has existed since December 2006.

Moving away from a fully unbundled connection requires the telephone service to be re-connected in addition to the broadband service and uses a process known as simultaneous provide. This requires you to obtain a Linked Order Reference Number (LORN) from either the new broadband provider or telephone provider, which is then used to link the ADSL and telephone orders together.

The costs of a simultaneous provide can be significant as it requires the payment of activation of a BT telephone line (either via BT Retail or another wholesale line rental provider) and this varies between around £60 and £125 depending on current offers and contract length. In addition there is the ADSL activation charge which varies between free and £58.75.

Now if you add a mobile phone or other service into the equation you can see how complex the problem can be, and to some extent this is why companies are promoting bundles heavily, they know that retention is better if you lock customers into more and more products. In the short term monthly savings can be achieved, but in the case of a fully unbundled connection if it costs £150 or more to go back to another provider at a later date this can wipe out a lot of the savings.

One area that providers need to brush up on is the awareness of the switching processes. Some providers have been known to reject a MAC from a shared LLU line as invalid. This is probably down to a providers own systems not being updated to accept the full range of codes that can be generated. Under current rules while a gaining provider is expected to provide reasonable assistance, they are not under the same obligations to accept a MAC from a customer.

A final comment for those who have dutifully obtained their MAC and are moving to a fully unbundled provider such as Talk Talk, note that they do not actually need the MAC. All Talk Talk need to know is that you want to move to them. This ease of migration to fully unbundled networks comes at a penalty--Every now and then someone pops up whose broadband service has mistakenly been moved.

This complex range of systems clearly illustrates that a unified system would go far to help consumers switch suppliers easily. Co-ordination of the systems to achieve this will not however be an easy task.