Ofcom’s September 2021 One Touch Switch (OTS) Statement announced the introduction of a seamless residential landline and broadband provider switching process in order to promote the take-up of faster broadband services whilst creating a more competitive telecoms sector (Figure 1). Ofcom’s revised General Conditions published in February 2022, confirmed that Internet access services (IAS), landline and all parts of bundled services would be included in the OTS process and set the timeframe for the service to go live on 3 April 2023. Key to the Conditions, was that given the sheer volume of potential switching requests, the new OTS procedure would require one industry agreed upon standardized process to be used by all communication providers.
The OTS process is a broadband sector first, as the trans-industry procedures would require providers along with various other stakeholders to agree upon, design and introduce the system in a relatively short period of time. At the request of Ofcom, The Office of the Telecommunications Adjudicator (OTA) brought together industry-wide parties to define OTS through the creation of the OTS Steering Group whilst the Detailed Design Group would draw upon the skills and expertise within the sector to establish the end to end processes for OTS.
From OTA’s findings, the industry established in June 2022 a not-for-profit organisation known as The One Touch Switching Company (TOTSCo) to take ownership of the Industry Process to implement the system. The company, which is limited by Guarantee, is comprised of members who pay a £50 membership fee and is representative of a ‘constituency’ within the sector, e.g. small, medium, large retail ISPs, business ISPs, infrastructure suppliers, etc. The company is currently being funded by loans from providers with later funding expected to come from the TOTSCo Hub usage fees, which are yet to be determined.
The TOTSCo Hub will act as the main OTS messaging platform for consumers and small businesses and essentially acts as an enabler of the switching process. Worth noting is that TOTSCo is currently in talks with the business / enterprise sector in order to agree upon an industry-wide process for switching as mandated by Ofcom.
The TOTSCo Hub
At its heart, the TOTSCo Hub will act as a message exchange portal that will utilise APIs and be comprised of 3 key areas of functionality:
Check consumer’s personal details along with logging losing and gaining providers details – this triggers the switching process with losing provider to begin termination and switching process
Consumer provides informed consent for the switch to take place
Gaining provider begins new customer service journey
The functionality of the Hub in its basic form will work similar to a post office where once the relevant data has been input, the post office will expose a letter box which can receive messages and send acknowledgement messages accordingly. The post office can also view and determine the type of information being sent along with the sender’s information which in turn allows the post office to access the directory, activate the gaining providers letterbox and send the request to the provider. The post office also contains an archive functionality which will allow for regulatory reporting and accounting purposes.
TOTSCo itself will not have the responsibility for the design and maintenance of the Hub as these along with system support services will be outsourced to a third party vendor. TOTSCo have issued several Request for Proposals (RFPs) to vendors in September with a submission deadline of 28 November, with further information about the successful vendor and its software solutions to be published by mid-December.
How ready are ISPs to implement OTS?
Compiled for the Independent Networks Co-operative Association (INCA) by Point Topic using data provided by independent ISPs, the June 2022 ‘Metrics for the UK independent network sector’ highlighted a lack of readiness by operators to implement the system. Seventy-two per cent of independent network respondents stated they were at beginning of the process compared with 8% who stated that they were substantially ready with most systems in place, with the remaining 20% stating ‘other’.
However, given that TOTSCo was in its embryonic stage at the time and no overarching finalised procedural guides were circulated, the results were not surprising. Given the short timeframe put forward by Ofcom, the industry has found itself testing systems that are not yet complete with many communication providers concerned over the eventual integration of their systems into a Hub that has yet to be designed.
During the latest TOTSCo Stakeholder Forum meeting held on 22 November, TOTSCo did report that there were 260 downloads of the Industry Process documents and 180 for the OTS Developers Guide.
Although the Hub has yet to be fully designed, the CEO of TOTSCo, Paul Bradbury, urged all providers to start rigorously testing their internal systems and those that wait for the Hub to go live, do so at their own risk. Several providers in the Forum meeting did again raise concerns about testing a system that doesn’t have a sandbox facility and lacks a finalised product, however TOTSCo were confident that the three recently published Industry documents were more than adequate to begin implementing the testing phase.
What Happens Next?
Now that the process is slowly moving forward it is evident that there is still some way to go in making substantial inroads to integrating the Hub into key stakeholders’ systems. TOTSCo have underscored this point by providing written notification to Ofcom notifying them that it is unlikely that the Hub and supporting procedures will be in place by the April 2023 deadline. Ofcom has acknowledged this but have yet to take any action to introduce a later introduction of the system. Moreover, TOTSCo currently do not have an alternative timeline of when the system will be ready.
The next significant progress update, including the notification of the outcome of the RFP and successful vendor(s) to implement the Hub will take place on 15 December. It is fair to say the industry will be waiting with bated breath as to the outcome.
 TOTSCO, Request for Proposal: TOTSCo Hub Specifications & Technical Requirements V.0.3.0, 30 September 2022.