UK Regulator Investigates Bill Audit Compliance

Ofcom, the UK communications regulator, has announced it will conduct an “own-initiative monitoring and enforcement” program with respect to rules that mandate independent audits of billing accuracy. In other words, they decided to check if telcos are complying with its billing audit regime, even though…

  • nobody has told Ofcom to do this;
  • no recent news story or scandal has prompted this; and
  • all sizeable UK providers of retail telco services already undergo these mandatory audits.

The last time Ofcom said something about auditing the accuracy of phone bills, it was the absurd claim that UK bills are so accurate that all the long-established accuracy targets had to be completely scrapped, because they might discourage the quest for perfection. Something funny must be going on, if Ofcom now says it has to conduct its own investigation into audit compliance, instead of relying on work already done by the auditors of each telco.

Per Ofcom’s statement:

Ofcom is now launching a monitoring and enforcement programme to assess CPs’ [Communication Providers’] compliance with the provisions in GC11.4 [General Condition 11.4 – the rule that requires bill audits] and determine whether any further action, including enforcement, is required in the event of non-compliance.

They go on to state:

Ofcom may initiate separate investigations of named providers… Alternatively, we may move directly under this programme to take enforcement action where, for example, Ofcom has reasonable grounds for believing that a CP is contravening GC11.4.

The most important part of Ofcom’s statement is what it leaves out. No clue is given why Ofcom is reviewing compliance, which comms providers might need investigating, or why enforcement action – including punishment – might result. No UK telco has ever been punished for non-compliance with General Condition 11.4. Over 20 years have passed since the regulator first demanded audits of telco bill accuracy.

Something must have prompted Ofcom to act. Perhaps the issue is that one or more businesses dispute whether this particular rule applies to them. Or perhaps a telco has been audited but disputes the conclusions reached by their auditor.

Sadly, the opaque workings of Ofcom mean we are unlikely to find out the truth until after the investigation is concluded. There may be no announcement even then, if no action is taken.

Ofcom often reminds the public that the purpose of its bill accuracy regime is to “maintain consumer confidence in the accuracy of bills”, although there is little evidence that the public is aware of it. In July 2014, Ofcom stated its bill accuracy regime “was generally working well”. Something must be working less well than hoped, though this low-key statement gives little clue as to where the problems might lurk. In the meantime, the best advice for customers is the same as it always has been: check your bills, and do not rely on anyone to check them for you.

Eric Priezkalns
Eric Priezkalns
Eric is the Editor of Commsrisk. Look here for more about the history of Commsrisk and the role played by Eric.

Eric is also the Chief Executive of the Risk & Assurance Group (RAG), a global association of professionals working in risk management and business assurance for communications providers.

Previously Eric was Director of Risk Management for Qatar Telecom and he has worked with Cable & Wireless, T‑Mobile, Sky, Worldcom and other telcos. He was lead author of Revenue Assurance: Expert Opinions for Communications Providers, published by CRC Press. He is a qualified chartered accountant, with degrees in information systems, and in mathematics and philosophy.