As countries prepare for the PSTN switch-off, tensions have risen over whether consumers are ready to make the migration to digital voice. We review the role governments have played in communicating about the switch-off and consider other challenges in readiness.
The deadline for the PSTN switch-off in the UK is rapidly approaching in 2025. However, operators, local government and civil society advocates, are raising alarms about whether consumers are adequately informed and prepared for the coming changes.
Stakeholders are pushing for a public communications campaign on the digital voice migration led by the Government. Examples from other countries show that Government-led campaigns are rare, and that a lesser level of regulator involvement in the process is more common.
When regulators in other countries have engaged with communications campaigns on the PSTN switch-off, messages tend to be regional and targeted. In France and Germany, regulators set parameters for operator-led communications while the regulator-led switch-off in Australia did result in a Government-led communications campaign.
Special attention has been paid to identifying and communicating with vulnerable consumers, especially those who rely on non-telephony devices which connect to the PSTN such as telecare devices. The Commerce Commission in New Zealand relied on consumers to identify themselves to their operator in order to receive additional support.
The PSTN switch-off also creates competition concerns if incumbents are able to leverage communications for undue advantages. For example, in Ireland, ComReg has prohibited Eircom from communicating directly with consumers which aren’t its customers.
In addition to public communications, UK stakeholders have raised concerns about data sharing and device testing as key inputs for a successful migration. Among all of these concerns, questions of costs and liabilities remain the sticking points.
The PSTN switch-off is coming soon to the UK, but raising public awareness remains divisively unsettled
In 2017, the UK was given its first notice to begin preparing for the eventual switch-off of Openreach and Virgin Media O2’s legacy PSTN networks. Now seven years on and one year out from the migration’s 2025 deadline, the public dialogue on the switch-off may have reached its most contentious point yet. While stakeholders including communications service providers, local councils, civil society and central Government have all voiced their interests in ensuring a smooth and efficient transition, the duty to communicate with and support consumers through non-voluntary migrations to digital voice services remains unsettled. At the heart of debate is the question of who is responsible for reaching unengaged or unresponsive consumers and accounting for consumers which rely on non-telephony devices which connect to the PSTN, including telecare devices and emergency alarms. In addition to concerns over the costs of such outreach, the questions of how and to whom information should be communicated linger, as well as what organisation is best suited to act as the messenger. While the Government has expressed that a centralised communications campaign led by them could create more confusion given the rolling and regionalised process of the switch-off, advocates have countered that any centralised effort would be an improvement, citing the fact that 27% of consumers remain wholly unaware of the process according to the Ofcom Communications Consumer Panel.
Since the pause of all non-voluntary migrations from the PSTN began in December 2023, the UK is still stuck in an uneasy limbo in the path forward for migrating disengaged consumers. While the Government has previewed its plans for a targeted communications campaign to reach telecare device users, the calls of industry, local governments and civil society for a general public awareness campaign led by the Government remain unanswered. According to responses from Assembly’s 2019 consultation for CityFibre on the broader copper to fibre switchover, communications service providers have found that such outreach from trusted messengers such as central Government and Ofcom would be more highly valued and regarded by consumers. However, looking to examples elsewhere in the world, government-run public awareness campaigns for the PSTN switch-off have been relatively uncommon. We’ve detailed the other ways in which governments have been active in communicating the change to digital voice to consumers and considered the primary concerns these varying levels of intervention have sought to address (see Figure 1).
When governments do communicate about the PSTN switch-off, campaigns are normally regional and targeted
Similar to the UK, the industry-led nature of most digital voice migrations around the world have led governments to leave the primary communication with consumers to communications service providers. However, some governments (including France, Germany and Australia) have stepped in to support, dictate and even lead public awareness campaigns on the PSTN switch-off. Though governments have intervened both proactively and reactively, these efforts have almost always been regionally based on the progress of the switch-off process and targeted to a specific goal or concern, such as mandating notice periods for consumers or supporting coordination between stakeholders.
In both France and Germany, the communications regulator took a more active role in raising public awareness about the PSTN switch-off. As one of the earlier jurisdictions to make the migration to digital voice, Deutsche Telekom and the Bundesnetzagentur (BNetzA) in Germany did not have the benefit of learning from the complications and mistakes of other jurisdictions. As a result, BNetzA intervened partway through the migration process to address an influx of complaints from customers who were forcibly migrated. Together, the incumbent and regulator wrote new notices to be delivered to impacted consumers with a mandated minimum of four months' notice before services would be discontinued. Conversely, Orange and Arcep in France have worked in coordination more consistently throughout the planning and early execution of the PSTN switch-off. That coordination has allowed for the French Government to create communications that both address the 2030 deadline for the withdrawal of all copper-based services across the country and provide information directed at particular regions based on the incumbent’s schedule for withdrawal. Arcep has also leveraged its power to convene in ensuring that communication is coordinated between industries by working with the French Telecoms Federation (the industry body for electronic communications operators in France) as well as industry associations representing lift providers and other impacted product manufacturers. In both countries, the operator remained responsible for communicating changes to consumers but did so within the parameters established by the regulator.
In Australia, the regulator-led PSTN switch-off became the exception to the rule. Since the National Broadband Network (NBN) was responsible for the retirement of copper networks throughout Australia, the onus of communicating the migration process to consumers fell to the Australian Government. Similar to the French process, the NBN worked regionally to communicate specific deadlines and requirements to consumers while incumbent Telstra and the Australian Competition and Consumer Commission (ACCC) provided more broadly applicable messages on nationwide deadlines and the steps consumers and businesses should be taking to prepare for migration. In preparing a region for an impending switch-off, the NBN leveraged relationships with communications service providers, local councils, and advocacy groups to reach consumers through local advertising, community information sessions and direct mail campaigns. This more comprehensive approach to public awareness served the NBN and the Australian Government in their dual mandates of achieving the commercial initiative of switching off the PSTN while satisfying the public policy aim of keeping consumers connected.
Some jurisdictions have tried to communicate directly with vulnerable consumers, but identifying those consumers proved a challenge
In addition to generalised communications on the digital voice migration, a number of jurisdictions have paid special attention to how vulnerable consumers have been reached and treated during the switch-off process. Given the ongoing debates in the UK on operators’ abilities to identify vulnerable consumers, it is unsurprising that the definition of what makes a vulnerable consumer and how to identify them has varied between countries. Commonly, operators and regulators have focused on consumers who rely on the PSTN-based landline services as their only communication service as well as consumers who rely on additional services, such as telecare devices, which are powered by the PSTN. Information about who these consumers may be is rarely accessible from a unified source, such as a local council department or operator database, if it is even tracked at all.
In New Zealand, the Commerce Commission crafted a code for protecting vulnerable consumers through the migration which relied on the consumer to identify themselves to their communications service provider. While the operator was required to provide all consumers with information about the standards they would employ to qualify a vulnerable consumer, it was the responsibility of any individual consumer to proactively reach out to their provider to confirm their status. Once operators had access to this base of information on vulnerable consumers within their network, they were responsible for maintaining regular and direct communications with those consumers. Even following the completion of the PSTN switch-off in a given region, communications service providers have been required to contact vulnerable consumers to ensure the continued functioning of battery back-up services which support access to communications and other network-reliant devices through power outages. While this system does provide additional support for vulnerable consumers who are made known to their operators, it does not necessarily achieve the aim of protecting all vulnerable consumers, including those who are disengaged and unlikely to actively communicate with their provider.
Regulators have also considered whether public awareness campaigns could create unintended and undue competitive advantages
Beyond concerns related to consumer protection, the PSTN switch-off has also raised a number of competition related concerns, both in the realms of wholesale regulation of fixed telecoms markets and at the retail level. How and to whom incumbents communicate information about changes in PSTN-based services has raised questions of undue competitive advantages. Regulators have moved to prevent communications service providers from citing the PSTN switch-off as a reason for service upgrades or switches unless and until consumers are set to be imminently impacted by a switch-off. Additionally, incumbents have been limited in their ability to communicate directly with customers of other service providers about the digital voice migration.
The Commission for Communications Regulation (ComReg) in Ireland set out measures to mitigate potential harms to retail-level competition in its framework for legacy network migrations, which includes the forthcoming PSTN shutdown. Under this framework, incumbent Eircom is barred from communicating directly with consumers to which it does not directly provide services. That responsibility is reserved for the consumer’s retail-level service provider which should receive appropriate notice from Eircom on its planned switch-off schedule. Similarly, ComReg does not require nor prohibit Eircom from conducting public awareness campaigns on legacy network migrations targeted to a general audience. However, the regulator does specify that any of these efforts, which could include billboards or digital advertising, should be conducted under Eircom’s Open Eir brand. ComReg noted that these restrictions were put in place to prevent Eircom from undermining or supplanting consumer’s communications with their retail-level provider.
Other switch-off preparation measures, including testing and data sharing, feature similar challenges related to cost and liability
While public awareness and consumer readiness for the PSTN switch-off has been a primary point of debate in the UK, attention has also been paid to the internal coordination needed among stakeholders to improve preparedness. As noted when discussing communications to vulnerable consumers, the limited and dispersed nature of the data available on different types of devices reliant on the PSTN has proven a key challenge for operators. While improving, the process of sharing data about telecare device users between operators and local councils has been contentious at times. Local councils are both likely to own and operate devices, such as lift phones and fire alarms, which rely on the PSTN in publicly owned buildings and act as an intermediary in the provision of telecare devices to consumers. As such, they can serve as important sources of information for operators seeking to better communicate with disengaged consumers which may need additional support during the migration. However, this data is often disaggregated across a number of council departments and can be costly and challenging to collect and share with appropriate regard to constituent privacy. If successful, data sharing could provide better insight in identifying and ultimately protecting vulnerable consumers as opposed to self-identification schemes.
Similarly, the coordination between operators and device manufacturers can prevent the failure of devices following the migration. While both Openreach and Virgin Media O2 have provided testing facilities for manufacturers to check the compatibility of their devices, the costs of testing devices with multiple communications services providers has prevented some from proactively mitigating technical failures. While analogue adapters have been used in some jurisdictions as a solution to device replacement or reconfiguration, both communications service providers and device industry bodies have agreed that these adapters are temporary mitigations, not solutions, and could create more consumer confusion in the long-run. Therefore, testing remains the agreed best practice in the UK for ensuring the readiness of PSTN-reliant devices.
Across both these issues of testing and data sharing as well as those related to public communications, the questions of costs and liability remain at the heart of the challenges currently plaguing the PSTN switch-off process in the UK. Without settling who must take responsibility for the public policy aim of protecting consumers through non-voluntary migrations, including the questions of who pays for additional outreach, the UK is likely to continue to see complications in conflicts in its legacy network migrations.
