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A new report from the Digital Communities All-Party Parliamentary Group (DC APPG) has been published, which examines the ongoing industry-led switchover from Openreach, BT and KCOM’s legacy phone lines to new digital (IP / VoIP based) networks. But it warns that, despite recent efforts, vulnerable users still face a “risk to life” from the switch.
Just to recap. The big switch-off was recently delayed to 31st January 2027 in order to give broadband ISPs, phone, telecare providers, councils and consumers more time to adapt (details). But the main focus of this delay was the 1.8 million UK people who use vital home telecare systems in the UK (e.g. elderly, disabled, and vulnerable people), which aren’t always compatible with digital phone services. Take note that for everybody else, the switching deadline is still technically Dec 2025.
The industry-led shift to digital phones is being driven by two major changes, including the looming retirement of copper lines in favour of full fibre (FTTP) broadband (inc. future exchange closures) and the fact that reliability of the old network is in decline (i.e. it’s becoming harder for operators to source parts and skills for older technologies). Not to mention that it is not economically feasible to maintain both the old and new networks long term.
Both the past and present governments have already responded to these concerns by encouraging the industry to adopt various changes (here and here), such as by ensuring that no vulnerable customers are migrated by the major providers (e.g. BT, Virgin Media, Vodafone and Sky Broadband) until their telecare systems have been confirmed to work with the new digital phone service.
In addition, many of those same providers have also recently introduced enhanced battery backup solutions, which can help to provide additional protection to vulnerable users during protracted power cuts (here). Not to mention that BT and Openreach are currently also working toward launching their Pre-Digital Phone Line (PDPL) product this year (aka – SOTAP for Analogue).
The PDPL essentially attempts to replicate how the old phone service worked, albeit over a more modern network (i.e. it does NOT require a broadband connection to function or require battery backup). But PDPL is only a temporary solution until 2030 (i.e. when mass exchange retirement starts), and it will only be available to vulnerable and edge use cases (inc. CNI) users on existing lines (not new customers) who would otherwise “face challenges” in migrating to IP based voice solutions by the deadline. But there is a catch as “PDPL is not compatible with lines connected to broadband“ (i.e. it’s for voice-only lines).
Findings of the DC APPG report
However, despite all of the above efforts, the new DC APPG report – ‘Care to Connect‘ – finds that the current industry-led approach has created a “complex landscape in what is a technical project with deeply personal repercussions“, while highlighting the previously covered deaths of two “vulnerable” Virgin Media Phone customers (here) – this is partly what led to the government putting more pressure on the industry over the past year.
The group is now calling for the role of government “to be clearly defined in digital transformation projects” and has made various other recommendations (see bottom of article), such as calling for Ofcom to require longer-lasting battery backup within broadband and mobile networks (e.g. 6 hours instead of 4 for “newly installed” street cabinets).
The report also supports the plan for a national awareness campaign (National Telecare Campaign), although it fears that “industry fragmentation has the potential to undermine the delivery of an effective NTC“. Witness evidence is said to have highlighted the critical need for “buy-in and support from the voluntary and community sector (VCS)” to deliver an effective communication campaign.
Concern was also raised about the overreliance of residents to self-identify as ‘vulnerable’ throughout the PSTN migration. Further evidence raised the potential risk of an increase in scam activity (i.e. fraudsters using the switchover to pressuring customers into parting with financial details etc.), and there is growing concern that this may worsen as a result of the national campaign.
Helen Morgan MP (North Shropshire), Chair of the APPG, said:
“The APPG agreed to fast track an inquiry into the PSTN migration and shine a light on the risks associated.
The digital switchover should be known and understood by every resident across the country to ensure the most vulnerable in our communities are protected.
Successive governments have not provided leadership or coordination to this programme, and it is now time for this new government to correct course. The risk to life if residents are not safely migrated is real. A digital transformation project of this kind cannot be allowed to be led by industry operatives alone.
Unfortunately, whilst a national campaign is essential, DSIT must urgently intervene to ensure coordination and provide clarity to the wider network of stakeholders. This will ensure the campaign has a strong ground-up approach to complement TV and radio adverts.”
The report makes a lot of fair points and recommendations, although it should be said that Ofcom, broadband ISPs and the government are already in the process of delivering on some of the areas they touch upon. In other cases, such as in terms of battery backup for street cabinets, the regulator has already softened its stance due to the costs involved (here), although it is still considering options for mobile networks (here). But ISPs have also been improving the customer side of things with better protection for homes (here).
Elsewhere, we’re not completely convinced that the complex and highly technical project would have been better managed if it was centrally controlled by the government (MPs haven’t exactly proven themselves to be terribly competent when it comes to modern telecoms networks), although much would depend upon the structure. In any case, this is more of a consideration for future projects than the PSTN switch-off.
We’ve summarised the report’s main recommendations below, although we recommend reading the report itself in order to get the full context. But one of the main problems with this report is that it comes far too late in the process, near the end of what started being planned around a decade ago.
Recommendations
National government
• The PSTN Charter should be updated to include the agreed supported journeys definition during the PSTN migration.
• The Department for Science, Innovation and Technology must set out how it monitors compliance with the PSTN Charter and the PSTN non-voluntary migration checklist.
• The Department for Science, Innovation and Technology must set out how it plans to enlist all CPs to both the PSTN Charter and the PSTN non-voluntary migration checklist.
• The Department for Health and Social Care (DHSC), working with the TSA, must take every reasonable step to end the sale of analogue-enabled telecare devices.
• The Department for Science, Innovation and Technology should deliver ringfenced funding that enables combined authorities/strategic authorities to improve capacity and capability of dedicated digital teams to coordinate and deliver digital transformation and adoption.
• Future digital transformation projects should be coordinated centrally by national government, leveraging local and regional government and industry representatives.
• A ministerial statement must be heard in Parliament ahead of the launch of the national telecare campaign to support awareness raising.
Local government
• Local authorities and housing associations should sign DSAs with all relevant communication providers, regardless of where they are at with the digital switchover.
• Local authorities should perform an audit of the technology they own to understand what might be impacted by the digital switchover.
Businesses
• Businesses should perform an audit of the technology they own to understand what might be impacted by the digital switchover.
Power and battery back-up solutions
• Ofcom, Ofgem and the Government should continue discussions on power back-up solutions. As a first step, Ofcom should update its guidance on resilience solution in the home during a power cut for customers reliant on their landline to call emergency services and to increase this from one hour to at least four hours.
• Ofcom should update its guidance to increase the minimum requirement for power back-up solutions from four hours to at least six hours for equipment in newly installed cabinets of fixed networks.
• Where battery back-ups are used as power solutions in the event of an outage, the battery back-up deployed should run for at least six hours.
• Resolving the issue of power back-up solutions should be a joint undertaking between energy and communication providers, with oversight from Ofgem and Ofcom.
• The APPG supports the creation of a multi-sector priority service register covering energy and communications.
• CPs performing the PSTN migration must undertake an audit with residents to understand what alternative means of communication they have in the event of a power outage and inform them of the support that is available to them, embedding Ofcom’s guidance as standard practice.
Telecare sector
• All telecare service providers and suppliers, including private providers and suppliers, must be certified to TEC Quality’s Quality Standards Framework to reach the highest standards on their digital switchover procedures.
2/3G sunsetting
• Data gathered on ‘vulnerable’ people through DSAs should be shared with mobile network operators (MNOs) as 2G and 3G sunsetting progresses. If this is not possible, the London Office for Technology and Innovation (LOTI) and the LGA should recreate a universal DSA for MNOs to use.
• CPs should be actively informing consumers about 2G and 3G sunsetting when performing PSTN migrations.
• Audits should be conducted by local authorities and businesses to understand what technology is owned that might be impacted by 2G and 3G sunsetting.