OPINION ITSPA
“ITSPA members were so worried by these proposals and their potential effect on the industry that we led a
lobbying campaign (engaging with Government, Parliamentarians and Ofcom itself) to highlight our concerns. “
Lee Turner, ITSPA Council Member & Industry Engagement & Regulatory Manager at Gamma
ITSPA urges industry to unite
The EECC is a new EU Directive which updates and replaces the four Directives that made up the EU regulatory
framework for electronic communications. In this piece, Lee Turner, ITSPA Council Member and Industry
Engagement and Regulatory Manager at Gamma, explains why the industry should be concerned
ITSPA has not kept quiet
about our dissatisfaction
with the previously
suggested implementation
of the European Electronic
Communications Code
(EECC), outlined by Ofcom in a
consultation in September 2019.
ITSPA’s most signi cant
concerns were related to how
Ofcom was interpreting the
Directive’s de nitions on
micro-business and small
business. Under Ofcom’s
original proposals consumer-like
protections would have been
extended to all businesses of
up to 50 employees. A business
of 49 employees will clearly
have much more sophisticated
telecommunications needs than
a residential user rendering
this new de nition totally
inappropriate as it would hamper
their business communication
requirements.
Additionally, Ofcom’s
de nition of a ‘not-for-pro t’
would have extended consumerlike
protections to all local
and central Government
organisations and multinational
charities, regardless of their size.
UK Government organisations
– many of which have very
signi cant spending power and
very large workforces –have great
bargaining power and clearly do
not require the same protections
as a residential consumer.
ITSPA members were so
worried by these proposals and
their potential e ect on the
industry that we led a lobbying
campaign (engaging with
Government, Parliamentarians
and Ofcom itself) to highlight
our concerns.
We were therefore very pleased
to see in late July that Ofcom
had decided to consult on new
proposals on business de nitions
and tari noti cations. Ofcom
set out a number of options
in the consultation, but the
one that they have indicated
they will adopt would see
them use a single de nition
across microenterprise and
small enterprise which would
set a headcount threshold at
10 sta members – a clear
improvement to the up to 50
employee threshold previously
proposed. is threshold would
also be applied to not-for-pro t
organisations, which would
address the serious problems we
identi ed with their previous
proposals.
Whilst ITSPA - along with
the other parts of industry that
have taken part in the campaign
- are pleased that our concerns
have been taken into account,
it is now essential that industry
responds to the consultation to
ensure the revised proposals are
implemented.
We encourage industry to
respond to this consultation
by 11th September 2020,
especially as there will be a
quick turnaround with Ofcom
planning to publish a statement
on this by autumn 2020, and
implementation of the EECC
beginning in December 2020.
is therefore really is the last
chance to ensure that Ofcom
gets it right and industry doesn’t
take a further negative hit as it
recovers from the impact of the
COVID-19 crisis.
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40 | Comms Business Magazine | September 2020 www.commsbusiness.co.uk
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