UK to Expand Regulatory Audit of Bill Accuracy

After handing out an unprecedented fine because a big telco kept screwing up the amount they charged customers, how should the regulator treat the auditors that failed to prevent that fiasco? By ensuring they get more work, obviously. That is the unfortunate conclusion of Ofcom, the UK’s comms regulator, per the new consultation it is running into consumer protection regulations.

Ofcom’s logic is not quite as perverse as I make it sound. The regulator wants to extend greater protection to customers because they spend an increasing amount on data, but existing audit rules exclude data from the scope of work done to assure billing accuracy. As Ofcom puts it in their consultation document, the reasons for extending the audit – formally known as the Metering and Billing Approval Scheme – is that:

Since we last considered the scope of application of the Metering and Billing Approval Scheme in 2013/2014, Ofcom’s complaints data shows a significant increase in the complaints related to the billing of data services. In light of this rise in the number of complaints and the progressive growth in the take up and importance of data services, our provisional view is that the Metering and Billing Approval Scheme should no longer differentiate between voice call services and data services and should become mandatory in respect of both.

They have a point. What they fail to mention is that there has also been a significant increase in the complaints relating to the billing of the voice services already covered by the regulation. So Ofcom’s proposal is to address the rise in complaints of overcharging by extending an audit scheme that already fails to address the rise in complaints of overcharging.

You have until 14th March to respond to the consultation, if you want. Ofcom proposes to make some other changes too, but none of them especially interesting. And you have almost no chance of persuading the regulator to fix any of the things they have messed up, because they have neither the competence nor the motivation to do better.

Eric Priezkalns
Eric Priezkalns
Eric is a recognized expert on communications risk and assurance. He was Director of Risk Management for Qatar Telecom and has worked with Cable & Wireless, T‑Mobile, Sky, Worldcom and others.

Eric was lead author of Revenue Assurance: Expert Opinions for Communications Providers, published by CRC Press. He was a founding member of Qatar's National Committee for Internet Safety and the first leader of the TM Forum's Enterprise Risk Management team. Eric currently sits on the committee of the Risk & Assurance Group, and is an editorial advisor to Black Swan. He is a qualified chartered accountant, with degrees in information systems, and in mathematics and philosophy.

Commsrisk is edited by Eric. Look here for more about Eric's history as editor.
  • Mike Willett

    Hi Eric, as you’d know the area of regulation for billing accuracy has held an interest with me for some time and for an unexplainable reason. The Australian equivalent code (ACIF518) by way of comparison has not been refreshed since 2006 and a casual inspection by an interested user will identify some gaps.
    One thing I have learnt though is that billing complaints and billing accuracy do not necessarily correlate. Let’s not debate the many reasons why this is the case but I hope that Ofcom is clear on that an expansion of regulatory coverage alone is not the only method for improving consumer protection outcomes.

    • You already know my opinion on your Australian billing accuracy code: it is excellent, and far superior to the regulations in the UK. Furthermore, it was written by the Aussie telcos, which is to their credit. The UK rules are inferior because so many UK telcos lacked the motivation and/or competence to write the rules they should have applied to themselves, just to protect their reputations, irrespective of what outside bodies think. This left a vacuum which was filled by even more incompetent people imposing badly-written rules instead. So when you talk about ‘gaps’ in the Australian code, keep in mind that it was fairly recently that the UK code was watered down by the removal of important objective elements about testing and test results, because of an Alice-in-Wonderland logic which says less proper auditing means an even tougher standard! And what has happened since those ‘improvements’ in the UK code? Big scandals and fines – so you tell me if the changes had the desired impact!

      You are right that billing complaints do not correlate to billing accuracy. But tell that to the useless UK auditors who put too much reliance on customer complaints to identify problems. If an audit scheme routinely relies on customers to spot errors, then the audit scheme is not fit for purpose. Instead of protecting customers, it waits for the customers to protect themselves, then tries to make work/paperwork whilst taking the credit for the customer’s efforts. It would be better to sack the auditors and use the money saved to pay customers an additional reward for every upheld complaint.

      Ofcom is not clear on whether the expansion of regulatory coverage will improve consumer protection or not. That is because consumer protection is not a credible goal of a scheme that does none of the things needed to protect consumers. The purpose is to deflect blame; if something goes wrong, you cannot blame the regulator because they have rules which say nothing should go wrong. It never occurred to them that these rules are often too subjective, and compliance too poorly measured, for any of the rules to be enforceable before a lot of customers suffer the consequences of prolonged and significant errors.