Mobile Bill Limit Legislation, October 2018
What is it?
New legislation is being introduced via Parliament as part of the Digital Economy Act, it’s coming into force from 1st October 2018 as part of the Communications Act. It will apply to all new contracts, including re-signs, taken out from this date and aims to significantly reduce risk of “bill-shock” for end users. The guidelines released by Ofcom can be found here.
What is the scope and what actions need to be taken?
Offer Bill Limit – each customer must be given the option to set an overall bill limit by account or by MPN at the point of sale/renewal from 1st October 2018, with the ability to manage this throughout the life-cycle as required with fair notice for the provider. Restrictions and spend values must be reset at the beginning of each bill cycle.
Notifications – must be sent to customers if they are coming close to reaching their limit and once they have reached their limit, notifications must be in writing by preferred contact method (SMS/Email).
Restricted Charging – providers are prohibited from charging beyond the set bill limit if a customer exceeds the amount and the service is not restricted or highlighted by the provider in time. Bill providers are responsible for supplier costs that cannot be passed on to the customer.
Premium & non-standard services still chargeable (in part) – providers will not be able to pass on “Access Charges” related to Premium and Non-Geo call types . However, relevant “Service Charges” will be passed on and will NOT contribute towards Bill Limit value. In addition, “Charge to Mobile” services or any non-mobile usage (such as MPAY) will not form a part of the Bill Limit.
Access bundles and free services – In the event a customer breaches their Bill Limit, providers must still offer end users access to inclusive allowances (like tariff allowances and bolt-ons), free-of-charge services and emergency services.
What are the biggest challenges with implementing this?
The biggest challenges to the introduction of this legislation are relevant to almost all ISPs and resellers, and those are:
Real-Time Billing – not currently available to Riviera Networks from network suppliers, meaning late landing domestic and roaming traffic could always cause issues with forward billing for customers with bill limits.
Restriction/Barring Capabilities – as covered above, the legislation outlines that suppliers should not restrict services covered within service charges (such as inclusive bundles and free services). However, the networks do not offer restriction to suit each and every instance, for example, if a user goes abroad to a WTS destination, they will receive the £5 per day charge until they hit their limit value. At that point the device will be roaming barred to ensure no further daily charges are applied. If that user then goes back to the EU within the same billing cycle they would be entitled to use roaming services. In instances such as this the customer will experience disruption in service that cannot currently be avoided.
What is being done to work towards implementing this?
There are a variety of things in progress, with both the networks and Riviera Networks, which will be subject to change as implementation approaches. Below we have listed some of these…
Vodafone – have clarified they will be working on ensuring rated CDR availability times are improved, this will still not cater for late landing traffic but will assist in reducing our reaction time to limit breaches. They have also confirmed that they are not working on new bars, but there may be existing restrictive “profiles” we can add that we do not currently use.
02 – have verbally advised they are considering new bars and working on a low risk proposition for ISP resellers that will put the risk with the network as opposed to the Partner. Please note that no official details have been clarified or released.
Riviera Networks – we must ensure that our customers have access to a bill limit service. If you are a business mobile customer of ours and would like to discuss your options please contact our support team.
Please ensure that you do not solely rely on any information contained within, you should contact your own Legal advisors in the event you need a comprehensive and up-to-date statement of the relevant Law/Legislation. Furthermore, please be aware that implementation of these regulations may differ from provider to provider (including networks), for example some providers may choose to include the service charge element of a call towards the customer’s bill limit. Customers may query this or other offerings included within the bill limit.