UKCTA Response to Ofcom Consultation
28 January 2026
About UKCTA
1. This submission is made by the UK Competitive Telecommunications Association (UKCTA). UKCTA is a trade association promoting the interests of fixed line telecommunications and broadband companies competing against BT as well as each other, in the residential and business markets. Its role is to develop and promote the interest of its members to Ofcom and the Government. Details of membership can be found at www.ukcta.org.uk. Its members serve millions of UK consumers.
Prevention of Harm
2. As an association, we are supportive of initiatives across Ofcom and government to ensure there is a robust response to fraud perpetrated over telecommunication networks and technology platforms. While consumer awareness is increasing, we broadly agree with the harms that Ofcom have laid out in the consultation. Our members are very conscious of the fact that tactics used by scammers are smart and we need to be proactive in order to maintain confidence in communications services, especially for A2P messages. We therefore support the proposed changes in principle and believe that alongside Ofcom, mobile operators should take proportionate steps to disrupt fraudsters and minimise scam activity.
3. We are pleased to note that Ofcom’s proposals align with the Telco Fraud Charter1 that all major mobile providers are signed up to highlighting a clear move in the right direction to build stronger networks against fraud. It is very important that wherever possible, across all forms of regulation or guidance (sectoral and general consumer law protections) that apply to communications providers, similar approaches are taken so as to ensure there is clarity and no risk to CPs of being non- compliant with one regime whilst compliant with another.
4. One issue which is not addressed in the consultation is that other messaging platforms such as RCS and OTT are also routes used by scammers to target 1 UK Telecommunications Fraud Sector Charter consumers. These platforms are increasingly utilised by consumers and are notably not controllable over traditional mobile voice networks. UKCTA strongly urges Ofcom to advocate for and support cross-sector liaison to combat fraud in this area. There is a real danger of a ‘whack-a-mole’ situation where the focus of the fraudsters and scammers merely shifts to alternative platforms, making these measures redundant very quickly.
Specific Comments on Draft Guidance
5. Training on policies, procedures and systems: The proposed condition C9.21 states “all staff” must be aware of, and appropriately trained on, the policies, systems and processes in relation to C9. This is clearly unrealistic and goes too far. We propose that this is rephrased to refer to “relevant staff”, as it does when referring to training relating to Condition C9.18.
6. Cross cutting measures: Right to challenge - clause C9.17 requires providers to “notify the person whose message they blocked”. In the event that blocked messages represent legitimate traffic, we will have appropriate channels of communication with the sender either directly or through an aggregator, and the maintenance of challenge and dispute processes as per C9.18 suffice to manage
potential ‘valid’ requests to reinstate traffic. In the event the message blocked is a scam, which we’d expect to be the vast majority, it’s unlikely the fraudsters would engage to dispute the block therefore by notifying them ourselves we’re playing into their hands and giving them early-warning that the traffic has been detected as scam, enabling them to pivot quickly. We believe this clause is obstructive to preventing fraud.
7. Ensuring transmission of legitimate messages: Clause C9.27 requires providers to “take appropriate steps to ensure the continued transmission of legitimate messages through networks”. This is a key business objective already for all legitimate parties in the value chain, and implementation of clauses such as C9.18 on right to challenge; C9.20 on effective policies; C9.21 on appropriate training; and C9.22-25 on record-keeping; as well as C9.12 on “know your traffic”, deliver the necessary framework to understand and manage traffic fittingly, therefore minimising the risk of over-blocking. This clause feels counter-productive to bring potential enforcement action against providers for over-blocking when our aim is to get more effective at collaborating across industry to identify scams.