BT's response to Ofcom's consultation "Approval of the ICSTIS Code of Practice (11th edition)"

Approval of the ICSTIS Code of Practice (11th edition)

Issued July 7, 2006

1. BT commented extensively on the ICSTIS consultation concerning the draft 11th Code of Practice, issued July 2005.  BT is pleased to see that ICSTIS have taken on board many of the comments raised by both BT and industry.

2. This has been a long and lengthy consultation period and it is good to see that the Code of Practice has reached the final approval stage prior to implementation.

3. BT is pleased to see that the Code of Practice allows for every part of the premium rate service (PRS) value chain to be regulated ensuring it is clear which party could be held accountable should problems arise. BT believes that this regulation is proportionate. 

4. BT is also pleased that the code is becoming more technology neutral and therefore more future proof and given that this market is evolving this is especially important.

5. BT suggests that a full review of the Code of Practice structure is needed to make it more user-friendly as it is now a large and complex document. Whilst the help notes will assist in addressing this complexity there is perhaps still a need for a check list for new service providers and network operators.  These areas are something that perhaps the Industry Liaison Panel can work with ICSTIS to address.

6. BT raises no objection to the approval of the ICSTIS 11th Code of Practice.

Please address any queries on this response to: nicola.robbins@bt.com