DSIT consultation on Proposed Statement of Strategic Priorities for telecommunications - Which? response

We welcome the opportunity to respond to the Department for Science, Technology and Innovation (DSIT) consultation on its draft Statement of Strategic Priorities (SSP) for telecommunications, the management of radio spectrum and postal services for 2025-2030. This response is focussed on the telecommunications sector, and in particular Strategic Priority 1 ('Driving growth through world-class fixed and wireless digital infrastructure') and Strategic Priority 3 ('Supporting growth through a transparent, competitive, and fair retail market'). 

The draft SSP's five-year window is a critical period for the deployment of fixed, mobile, and wireless infrastructure. Reliable, accessible and fast connectivity will be critical for consumers in the UK economy. Additionally, the UK Government has recently set out a vision for the digitisation of Government and public services which will be catalysed through the connective fibres of resilient, high-performance communications networks. But despite the potential for telecoms services to drive transformation and innovation in both public and private spheres, little sense of a vision or a strong strategic position emerges from the draft SSP. 

Our main recommendations are: 

Strategic Priority 1: Driving growth through world-class fixed and wireless digital infrastructure

• Network modernisation: DSIT must urgently communicate and implement a clear plan for managing the transition from legacy networks (copper, PSTN, 2G/3G) to digital networks. This includes ensuring that consumers have the right information and support to migrate to new digital networks. Ofcom must work with communication providers to proactively identify vulnerable consumers and ensure robust and consistent processes are in place to mitigate the risk of disruption and harm to consumers.
• Infrastructure reliability and accessibility: DSIT must proactively support infrastructure reliability and accessibility - raising the Universal Service Obligation (USO) threshold; strengthening Ofcom’s Broadband Speeds Code of Practice; and imposing quality of service obligations on mobile networks.
• Fraud and economic growth: Fraud represents a major threat to the growth and productivity of the telecoms sector and the wider economy. DSIT must drive a proactive approach from the sector to prevent fraud, and be prepared to take action if it finds the existing legislative framework is ineffective.

Strategic Priority 3: Supporting growth through a transparent, competitive, and fair retail market 

• Customer service: Ofcom must provide better monitoring and enforcement around customer service. Which? research finds that UK broadband customers were collectively an estimated £94 million worse off between May 2023- May 2024 due to poor customer service. 
• Pricing and providers: Ofcom should formally evaluate the impact of recent changes to mid-contract price rises; and mandate that providers give clear, upfront information at the point of sale about the price customers will pay if they do not recontract once their initial term ends. Ofcom should also adopt a more proactive communication strategy to encourage customers to engage with the market and highlight the advantages of the One Touch Switch process.
• Affordability: DSIT must develop a strategic long-term plan to support consumers who struggle to afford connectivity. In the short-term, DSIT must ensure the current voluntary system of social tariffs is proactively communicated to customers by communication providers. According to Ofcom only 9% of eligible consumers have heard about social tariffs from their provider.
• Smart Data: DSIT must urgently commit to a smart data scheme in the telecoms sector.

Conclusion

Consumers must be at the heart of the draft SSP vision as the demand for telecoms services is a critical enabler of economic growth.  But telecoms consumers are strikingly disengaged: the 2024 National Centre for Social Research Consumer Detriment Survey finds that 'internet provision' has one of the highest rates of consumer detriment (24%) across all market sectors surveyed. This issue cuts across both Strategic Priority 1 in relation to network quality, and Strategic Priority 3 relating to the effectiveness of the retail market.

We believe it is important that the government communicates a meaningful long-term vision for confident and engaged consumers in the telecoms sector, reflecting the strategic importance of telecoms to the digitisation of economy and society.