11 Ofcom Consumer Switching final statement Next steps for BT Bev Bytheway-Jackson WBC Product Manager 10 th February 2014

22 Final statement (first phase) – key points Scope remains: –Voice and broadband switching within Openreach network –Residential and small business customers (NB all customers affected) –Other networks (cable and FTTP) and services (Pay TV?) in next phase Conclusions from consultation: –Implementation of the move from MAC to Notice of Transfer (NoT) for all voice and broadband switches to be complete by 20 th June 2015 –All proposed “front end” enhancements to NoT to be adopted and implemented by 20 th September 2014 –First industry working group meeting 22 nd January 2014, chaired by Ofcom and supported by OTA Second phase: –Further examination to consider - the extent and cause of erroneous transfers (largely as result of Working Line Take Overs) - feasibility of extending to include other technologies, networks and services - further development of NoT, or hub/database solution –Details and timeline to be published in Spring 2014

33 Openreach proposed milestones for move to NoT  January 2014Industry working group to agree governance arrangements and underlying principles of harmonised process  March 2014Stakeholder agreement on implementation strategy  April 2014Stakeholders to submit Implementation Commitment Plans & agree e2e process  May 2014Openreach to issue straw man interface spec, CPs to begin detailed design  June 2014Wholesale CPs to submit straw man of their interface spec  October 2014Openreach and wholesale CPs to confirm detailed design  November 2014Openreach and wholesale CPs to publish final technical spec and CPs to begin interlock testing  January 2015Final release of Openreach systems updates for CP testing  January-June 2015Business readiness and testing  June 2015Launch of harmonised switching process

44 Points to note about NoT implementation Ofcom have opted for a “big bang” approach Ofcom recognise that this requires more co-ordination and collaboration across industry than “normal” changes A number of issues for further debate within the working group, such as: - mandatory use of RIDs on SMPF and FTTx - application of emergency restoration process - KPIs required to support enforcement - strategic KCIs needed from wholesale CPs on losses/ceases Acknowledged that switches of larger businesses might be impacted, but regulation will not apply, so down to commercial negotiation with Openreach

55 Enhancements to NoT  Record of consent –Call recordings of telesales, “I agree” button for online orders –To include direct record of consent, explanation from CP that it is required to create this record, customer name & address, time, date & means by which consent given, place (where appropriate), address and CLI of target line –Retrievable on an individual basis and retained for 12 months  Provision of better info on implications of switching –NoT letters to contain precise info on ETCs, including means by which they must be paid, calculated according to planed switching date –impact on ancillary/retained services, including price, specific to consumer –clear statement that customer does not have to contact LP  Mandatory use of functionality to ensure seamless transfer of bundled services with no loss of service (e.g. Sim provide, Linked Orders, SIM2) where customer makes a single request to one GP  Mandating some best-practice elements of Working Line Takeover (WLT) process ₋ No WLT order placed without exact match; GPs to take all reasonable steps to identify ₋ Notification letter to “incumbent” customer, via post or another durable format if agreed

66 To be considered in future phase: Options to address “poor quality Openreach address data – a major cause of Erroneous Transfers” Whether recent industry developments, such as the MPF helpline, are sufficient to address lack of visibility of key data in identifying correct line Whether a harmonised process giving consumers a similar end-to-end process regardless of underlying technology is possible (e.g. for moves to/from cable) Whether further enhancements to the AoT process are needed (e.g. mandating use of Cancel Other Whether a new GPL solution, based on Transfer Code and an industry database, may be necessary and proportionate