Posted on: 31st August 2023, by Magrathea
Nobody in our industry can be left with any doubt that preventing scam calls and protecting consumers is a priority with a lot of pressure coming from regulators and government to get this under control. This is also a priority in other countries too and the Irish regulator, Comreg, have recently consulted on this topic.
Comreg have already strongly encouraged voluntary interventions but felt things were moving too slowly so are now seeking to update regulation to bring about change.
The Irish telecoms market is of course a bit different to the UK. It is a smaller market overall and the supply chain is generally shorter with fewer service providers in the game, this does mean that mandatory interventions on the bigger networks and providers should have a dramatic effect.
The technical changes that are almost certainly going to be mandated for voice include:
- Fixed CLI Blocking – to stop fraudsters abroad spoofing Irish geo numbers
- A Protected Number List – to stop fraudsters using numbers that are not allocated
- A DNO list – to prevent calls being originated with CLIs that never make outbound calls
- Mobile CLI Blocking – to stop fraudsters abroad spoofing Irish mobile numbers
- Voice-firewall – to block spam calls at the point of termination based on known data
Fortunately for our clients, we adopted the first three measures on the list earlier this year. Perhaps the most demanding requirement remaining is voice-firewall but Comreg propose limiting this one to only the largest operators serving the residential market in Ireland.
As well as the above, Comreg also considered STIR/SHAKEN as a potential solution. Noting that this has been adopted in USA, Canada and France and is of course under review in the UK, Comreg are not minded to introduce this solution claiming that it is not a valid option at this time. Something we currently agree with for all the reasons they set out in their document.
Perhaps the most interesting inclusion in this consultation though is the proposal to prevent sub-allocation of telephone numbers in Ireland. We were somewhat alarmed to find this being included in a consultation about scam calls, in fact we have responded quite strongly that we feel this must have a standalone consultation.
The reasoning they included this is clear, as Comreg believe that by preventing sub-allocation of numbers they will retain better visibility of who is using numbers and therefore can better manage bad behaviours. However, the impact this would have on the entire market-place is the reason we believe this particular point needs to be considered as a separate consultation.
Therefore, we have responded to vehemently disagree that the benefits of Comreg having direct control over every number is proportionate or helpful when you factor in the considerable benefits of a healthy multi-level supply chain. Of course, Magrathea have built a business around managing service provider relationships and efficient use of numbers across a wide customer base so we feel very strongly that to block this business model would be detrimental to the industry. Not to mention increase costs, add barriers to market entry and generally bring about an administrative and technical burden for very little benefit.
Whilst we are entirely supportive of efforts to reduce scam and nuisance calls, we are also realistic. CLI spoofing, finding loopholes in routeing rules and using unscrupulous or incompetent third parties can all result in scam calls and no amount of visibility by Comreg on number allocations will eradicate this completely. So again, it all comes back to proportionate interventions, and we sincerely hope that Comreg decide a ban on sub-allocation of numbers is not one and leave us all to continue to provide new and alternative solutions to the Irish market.
Meanwhile, in an earlier separate consultation and statement on Universal Service Provision for voice services in the fixed market, we learn that Ireland is under-served by the VoIP market so this backs up our belief that we need to do more to promote a simple route to market and a competitive environment for service providers.
With Eircom’s universal service obligation (USO) ending this summer, Comreg had to analyse the fixed voice market and decide if a USO was still appropriate. They found that there are only two providers (Eir and Pure Telecom) offering a standalone voice solution in fixed locations.
Comreg have already consulted on the alternatives, including mobile and OTT services but neither were deemed a ‘voice communication service at a fixed location’. Here it’s worth clarifying that OTT services are defined as those that do not rely on phone numbers to communicate (e.g. WhatsApp), as opposed to VoIP which is classed as a number based interpersonal communication service (NBICS).
Comreg state that there is currently no wholesale service limited to voice only in the residential market in Ireland and therefore this is not a viable alternative and will not justify the removal of a USO.
The consultation closed in July so we will watch with interest but the most likely outcome, indicated by Comreg, is that Eir will have a USO requiring them to continue provision to all existing fixed line customers and Pure Telecom will have a USO requiring them to provision fixed line services to new customers.
If any of our clients would like to discuss what services we offer in Ireland please do get in touch, clearly there is a market waiting to be tapped!
The full consultation on scam calls can be viewed here: https://www.comreg.ie/media/2023/06/Consultation.pdf
The statement and consultation about universal service provision can be viewed here: https://www.comreg.ie/media/2023/06/ComREg-2355.pdf