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Changes to the General Conditions of Entitlement: an update

Changes to the General Conditions of Entitlement: an update

  • United Kingdom
  • Technology, Media and Telecoms - Telecoms


Ahead of the revised General Conditions of Entitlement (“GCs”) coming into force on 1 October 2018, we explore Ofcom’s latest statement and in particular its changes to General Condition 6 (“GC6”) relating to new calling line identification (“CLI”) requirements and ensuring that calls to emergency organisations are never blocked.


Since 2015, Ofcom has been reviewing its GCs (the regulatory rules that govern the operation of all communications providers (“CPs”)) with the aim of delivering simpler and clearer conditions which reflect Ofcom’s current priorities and concerns. One of the main changes in Ofcom’s latest statement dated 30 July 2018 (statement on changes to the General Conditions of Entitlement) concern GC6 and related guidance on the use of CLI facilities and the importance of connections to the emergency services. One of the new requirements under GC6 is to require communications providers, where technically feasible, to take reasonable steps to identify calls for which invalid or non-diallable CLI data is provided. Ofcom’s statement intends to clarify that calls to emergency organisations should never be blocked by amending GC6.6 to address this point.

So What?

CLI facilities enable recipients of calls to identify the caller by displaying a caller’s telephone number. These facilities, alongside giving call recipients the ability to decide whether to accept calls based on the number being displayed, assist with the identification, tracing and prevention of unwanted nuisance calls.

As part of Ofcom’s consultation undertaken in April 2018, the importance of calls made to emergency services was emphasised and in particular that: (i) calls to emergency services should never be blocked, regardless of the validity of the CLI data provided with a call; and (ii) all necessary measures should be taken to safeguard uninterrupted access to the emergency services. In light of this, Ofcom has proposed amending GC6.6 by excluding from the requirement to take all reasonable steps to identify calls where invalid or non-diallable CLIs are provided calls to emergency organisations. This has the effect of requiring all calls to emergency organisations to be completed irrespective of the status of the CLI and ensuring there is no justification for them to be blocked.

Following this change to GC6.6, the CLI guidance has also been amended. Though not legally binding, the CLI guidance provides recommendations on how CPs should meet their responsibilities in respect of CLI facilities. The amendments to the guidance, which have had the support of Stakeholders, state that connections to the emergency services should always be ensured as opposed to blocking or filtering them as if they were non-emergency calls.

With the implementation of Ofcom’s new set of GCs now imminent, the latest changes to the GCs look to further achieve Ofcom’s aim of safeguarding consumer interests whilst at the same time clearly identifying the requirements CPs need to comply with moving forward.

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