Final Report for Ofcom by Deloitte and Touche LLP

Issued 19 February, 2008

Introduction

• BT has carefully considered the report prepared by Deloitte and Touche for Ofcom and welcomes the opportunity to comment on this analysis and the report’s recommendations ahead of Ofcom setting out its proposals for regulatory actions in a further consultation paper. However, BT believes the report fails to recommend a proposal which fully addresses the fundamental problems faced by UK consumers in relation to the transfer of voice and broadband services between suppliers.

• This response sets out the principles that BT believes Ofcom should follow in assessing options for transfer processes and proportionate and appropriate regulatory actions to improve the overall customer experience in relation to transferring voice and broadband services between suppliers. It then assesses why the recommendations put forward in the Deloitte report fail to align with these principles and considers alternative approaches.

• Clearly, BT’s position as the provider of key wholesale services having ultimate operational responsibility for transferring many of the voice and broadband services under review means that BT businesses are likely to have significant responsibility relative to other communications providers for implementing and operating any new proposed processes. This response therefore also sets out principles which BT believes Ofcom should follow in considering how any proposals designed to improve the customer experience are introduced.

You can download the full response as a PDF document