Regulation of VoIP Services

Issued May 18, 2006

Executive Summary

VoIP services illustrate the power of technology to transform markets, by introducing greater competition. We believe that technology and competition are creating convergence of all voice services, including mobile, into a single market, within which no supplier has SMP. 

However, to achieve this end result, BT believes it is essential to have the right technical and regulatory framework in place. For this reason, Ofcom should be wary of imposing the same requirements on VoIP as on PSTN, or of withdrawing an Interim Forbearance policy that has eased the regulatory burden on both innovative new entrants and established players. This may well risk stifling innovation and growth and create consumer disbenefits, such as the possible withdrawal of 999 services. 

We believe some of the proposals will take longer to implement than Ofcom currently anticipates. Whilst we agree that the proposed Code is an appropriate way to promote consumer awareness of VoIP services, we feel it will more likely take three months than one month to implement properly. Similarly changes to Geographic Number Portability arrangements mean that some of the scenarios to import and export numbers across and between VoIP services are technically extremely challenging and likely to have delays in implementation. 

At least two unexpected consequences may frustrate Ofcom's policy objectives. First, some VoIP providers may use the current proposals to obtain Number Portability without the provision of 999 access, by concatenating two separate services, neither of which offers 999 access. Second, customers seeking to adopt VoIP services may face unexpected disruption and unwanted change of PSTN supplier. This is because,  current number portability legislation and industry processes require that requests to port a PSTN number to an ADSL based VoIP provider result in a cease of the customer's PSTN line and broadband service.

Voice as an IP application, decoupled from the underlying network, creates challenges in respect of consumer protection, emergency access, public security and compliance with General Conditions 3 and 4. We seek guidance from Ofcom clarifying the standard that risk assessments must meet for VoIP service providers to comply with these General Conditions. 

We look forward to taking various aspects of the VoIP debate further with industry, particularly in the areas of network integrity and Number Portability. 

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BT welcomes any comments on its position as laid out in this document. Comments should be addressed to Stephen Dean by email to stephen.h.dean@bt.com