Ofcom has launched another consultation on non-geographic numbers. See the news release:

Simplified call charges to help consumers

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A representative of the Fair Telecoms Campaign will be discussing this consultation on BBC Radio Wales this morning at 6:45am (click the link to listen online).

The topic will also be discussed on the Annie Othen Show on BBC Coventry & Warwickshire at 10am this morning.

This may sound like I'm being negative but I'm not yet convinced this unbundling will make much difference.  I have only scanned the summary as the indepth consultation is obviously designed for stakeholders.

Yes, I agree that it will be more transparent but that's about it.

A company using a 0844 number now that state, "This call will cost you 5 pence per minute on a BT line, calls may vary on other landline providers and cost considerably more on a mobile".

Presumably under the new proposals this would be advertised as 'Calls cost 3ppm plus your phone company's access charge'

Now to me, the first one gives as accurate as reasonably can be description of the cost of the call per minute.

Most people don't know how much their own telecom providers charge for calls now despite that they are obliged to provide this information on their website but even now it's rare to see this as its normally buried away somewhere hard to find along with the cost of calls in general (not just to NGN ranges).

I'm guessing here but presumably the money that OCPs get from calls to 0844 (costing 5ppm now, for example) is about 2ppm and although it varies between OCPs its approximately the same.  The remaining 3ppm obviously being split between the TCP and the called party.

The only main exception to this, that I know of, is VirginMedia who charge the most for calls to 0844 numbers so VirginMedia probably get a lot more than in my example above.

Now even if Ofcom tries to make the OCPs provide information on their 'access' charge under the new proposal then there is still no guarantee that anyone will look on their OCPs website for such information because they'll probably hide it like they do now even though they aren't meant to.  That is, assuming, everyone has access to the internet to get this 'access' charge information.

I believe (although I don't want to) that most joe public wont bother with the hassle of trying to determine how much this 'access' charge is hence will just assume (or hope) that it's not far from the 'service' charge description they have seen (ie 3ppm in this example).

As for name and shame a company over their 'service charge' isn't likely to be that effective because they can just say that the TCP receives the most money and it is used for intelligent call routing etc.

The good thing is about this unbundling is that it will highlight just how much money VirginMedia get from the call compared to other OCPs.

The fair telecoms campaign has drawn up a guide for responding to the consultation.

Unlike the consultation itself, our guide is short an fits on two A4 pages. The consultation runs to over 900 pages, including annexes!

We believe that consumers should support the proposals of the unbundled tariff. This will hopefully bring much-needed clarity to what is happening now.

It's taken a long time to get this far, and I wouldn't disagree with anyone who says that the regulator has wasted time, but we are where we are. The changes being put forward are major and therefore perhaps justify the monumental size of the consultation. Hopefully, the regulator cannot be accused of not considering and consulting on the many aspects of the changes.

The precise impact of the unbundled tariff will depend on how it changes behaviour.

Where organisations currently give an “honest” indication of the call cost (typically by giving only the BT pence per minute rate) and will continue to use the same number, then little will change. The amount will essentially remain the same, but it will be made clear that this is the charge that they levy in addition to what is charged by the telephone company.

There are very few who make this clear at present. Even bbb_uk has been misled into thinking that BT currently retains some of its charge, when it is prevented from doing so by regulation, which will be removed under the new regime. It is BT which is the exceptional case, not Virgin Media, albeit that the latter does have some odd ways with its charges.



With a single “Access Charge” rate to cover all non-geographic calls, there will be two effects. Firstly, telcos will be required to keep this low as a result of the transparency it will have in comparison tables etc. Even though this will only directly affect those who look at prices, there is enough competition in the market for all to benefit as a result. Secondly, the fact that it is a single figure per tariff, will mean that there is no justification for hiding it and there is some chance that those who care about costs will note and remember it.



Although provider’s telephone tariffs will still have to include extensive tables for the costs of international calls, the lengthy and complex tables of rates for UK non-geographic calls will simply disappear from individual tariff publications. There will be just one UK table which gives the bands and rates of “Service Charge” applicable to all ranges of non-geographic numbers. This will be published either by Ofcom, or by the industry body that will take responsibility for maintaining it.

The responsibility for advising the level of “Service Charge” to consumers will apply to the Service Provider and it will have to be given for each number, avoiding the need to look at complex tables of charges. The published table will only be required by the telcos for the purpose of billing and by consumers in the case of disputes.



It is my belief that the obligation to declare the Service Charge will have the most significant impact on those who could not do so. I believe that many current users of 0845 and 0844 numbers will be compelled to migrate to 03 numbers or return to geographic numbers, simply because they could not sustain or justify the open imposition of a charge on callers.

Where, for example, a 0845 number is used for a contact centre, I cannot see how one could justify a charge of 10p for a call that lasts 5 minutes when the cost of handling that call is likely to be in the region of £5. If there is any justification for charging the caller, then the charge should bear some relation to the costs involved. I am happy to make this argument, because I think it unlikely that many will adopt £1 per minute PRS numbers for these types of service.


We must also remember the impact of Article 21 of the Consumer Rights Directive, which must be incorporated into UK legislation by the end of 2013 to take effect in 2014. (See this link)

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(Article 17 confirms that this “shall apply to sales and service contracts and to contracts for the supply of water, gas, electricity, district heating or digital content”)

With an unbundled tariff in place, there can be no silly arguments based on relative call costs to suggest that 084 numbers are ever charged at “the basic rate”. The very statement that the requirement “shall be without prejudice to the right of telecommunication services providers to charge for such calls” makes it very clear that the separated Service Charge causes the consumer “to pay more than the basic rate”.


The Consumer Rights Directive does not apply to public sector service providers or their agents (e.g. NHS GPs). The clear separation of the Service Charge will however ensure that the government takes a clear line on how it raises money from citizens. If it wishes continue to impose or permit a charge on access to NHS services by telephone, on those enquiring about their taxes, benefits or state pensions and on those seeking help getting work, then it must be clear and open about this.

I personally think it unlikely that the present government would be prepared to argue that this is a valid way of addressing the deficit, however we will shortly be able to see it address this point directly.



The fair telecoms campaign is engaged in drawing these forthcoming provisions to the attention of those who will be governed by them. We see every reason for both private and public sector organisations to come to terms with the reality which will shortly be reflected in regulation and take the necessary steps now, rather than being dragged kicking and screaming into doing the right thing.

If you need a non-geographic number, but cannot justify imposing a charge on those who call it - switch to 03 NOW

How will it work in practice? I'll guess the vast majority will fail to state the prices or will inadvertantly mangle the wording to hide the costs.

http://www.google.com/search?num=100&q=0845+AND+"local+rate"+OR+"lo-call+rate"+

Nearly every telecoms provider still erroneously refers to 0845 numbers as "local rate" or "lo-call rate" many years after this became untrue.

Look back in another five years and I'd expect the vast majority to still have that wording. Ofcom can write 800 page documents or 8000 page documents but there's no way they will be able to force 700 000 websites to adopt new wording. They haven't got the manpower to begin checking yet alone send out a load of letters and emails.

The biggest problem is that companies don't update their website content very often. Even if they received a letter telling them that the wording for 084 numbers must be updated, most would have no clue where on their website all instances of such wording occurred. Many others would fail to identify that they need to make any changes at all.

Although not quite the same thing, evidence for the lethargy can be seen in the number of companies that still believe that London has three area codes: 0203, 0207 and 0208, Southampton has two area codes: 02380 and 02381 (all incorrect for 12 years now), Bristol has two area codes: 01173 and 01179, and Sheffield has two area codes: 01158 and 01159 (all incorrect for 17 years now). Many compnies can't be bothered to get their own phone numbers right, why would they now spend extra effort to clearly inform their customers they are also being charged a premium to place the call?

Any such change by Ofcom would need a huge publicity campaign to get even 10% compliance. It's a nice idea but in practice it is likely to be ignored by the vast majority.

Dave wrote on Jun 24^th, 2012 at 12:36am:
Can I clarify what you mean by expected?  Is it Ofcoms intention that this will be mandatory or that simply they hope OCPs will be forthcoming?

Going by past experience, a few years ago Ofcom changed General Condition 14.2 so that OCPs would make more prominent call charges for NTS number just as they did their geographical call charges.

I bet you now a lot of OCPs don't fully comply with this GC.  In fact, looking at BT's website they don't even mention how much calls to geographical numbers cost or even provide an easily accessible link to see call charges.  I bet if I was to spend the time looking I could find it but who is going to do this?

So basically if they don't do this now even though they are obliged to then why will it change under Ofcom's new proposals?

Just looked up costs for what I assume would be advertised now as a 5ppm call (a 08 'g20' call).

BT (when I eventually found it) said it costs 5.05ppm and on TalkTalk it's 5.06ppm.

Basically, as I said earlier, most OCPs last I checked generally charge around the same so the old pricing is more accurate to the true cost of the call.

But this exact same call under the new proposals would mean it's advertised as (just guessing) 3ppm service charge and then us joe public then have to know what the price of the Access Charge is and if they (the OCPs) go out of their way to hide like they do now with calls to NTS numbers then joe public will be worse off and more confused about the cost of these calls.