Telecommunications Adjudicator update for October 2025

At the end of October 2025, the number of unbundled lines stands at 3.84 million. There are 1.17 million WLR lines and the number of telephone numbers using CPS is 0.42 million.  *

The following is an update on the principal areas of project activity being led by OTA2.

Passive Infrastructure Access

Demand based on build remains flat and operational performance remains good. There is increased activity in the customer connection space as CPs leverage their built networks.

Unauthorised Use: Contract schedules have been agreed and notified (90 Day notification clock now running). Openreach have shared data identifying areas of discrepancy for the CPs to validate. CPs are being reminded that the grace period to work with Openreach to notify any problem areas runs to March 26.

Incident & Planned Works Management: We continue to monitor how this embeds into the process of Openreach/CP interaction. We have seen an uptick in incidents where overbuild activity is impacting other networks, we will continue to monitor and encourage better controls of contractors.

Beyond Build: Outline of target areas agreed with an initial plan of works set to kick off in November. Presentation to be given at the Ofcom CEO round table.

Other areas of interest:

• Health & Safety and good working practices
• Connecting Customers

Ethernet

Overall Performance is good. The order profile remains subdued, compared year on year it is circa 13% lower. The workstack has dropped well below 15k, which begins to raise some challenges with fluidity and the impact on reporting.

Whilst there is consensus that performance is good, the discussions on the way that performance is measured are on-going. The delivery process has been reengineered to take account of the lessons learned from quick win and swift, which fundamentally change the touch points for gathering data to report on performance.  

Areas of interest:

EAD2:  Good progress trial orders beginning to flow.

Exchange Exit: Most of the large CPs have now signed up for the commercial offer. The next stage is to get trials underway to prove the new hardened process for migration and to test the scheduling of circuit cutover.  

Copper and Fibre

A collaborative review of the KCI2 Assure process, utilised for complex orders, was undertaken between industry and Openreach over the first half of 2025. Several areas of focus were agreed and are being implemented.  Openreach anticipate performance to improve over the remainder of the financial year and will be tracked as BAU. It was agreed that the IWG had fulfilled its original intent, so no further meetings specifically on the KCI2 Assure are planned pending completion of the agreed work packages. However, a separate IWG initiative has commenced focused on the continued improvement of business orders covering aspects such as improving contact information, enhancements to Direct End Customer Contact, etc.

Industry engagement to develop a set of customer-centric FTTP metrics was completed in the quarter with 8 FTTP metrics agreed between CPs and Openreach.  These metrics, plus the initial targets (where applicable) were communicated via the CFPCG and SMF in September, and are being reported monthly to SMF and quarterly to CFPCG. To date, the feedback on their introduction has been entirely positive.  The discussions to agree the 2026/27 targets will commence end Q4 2025, initially via CFCPG, to outline the broader expectations, then via SMF to complete the detail

A final version of the Best Practice Guide to support Business Standard orders has been published following agreement by Industry.  Openreach are now developing a new Residential BPG, with the initial draft expected shortly.

Discussions between CPs and Openreach regarding contract changes to support the Telecom Security Act remain problematic with little progress made. CPs and Openreach consider that the TSA requirements are less suitable to network operators as suppliers, as opposed to equipment vendors. There was also, consensus that an industry attestation scheme would be highly beneficial in overcoming many of the contractual issues identified. This needs to be progressed via NICC and CPs were asked, via their NICC representative to support the development of such a scheme, however, this does not appear to have gained any momentum.  In the absence of an attestation scheme, CPs agreed to review the M10 measures and identify those where they need Openreach assurance. CPs were asked to consider this in the context of the sensitivity of the detail they are requesting Openreach share and frame their asks appropriately. As part of the B/Openreach response to the TSA a mandatory audit of all 3rd party proximity cards is underway, which is due to complete within this calendar year.

Openreach are modifying their WLR supplier of last report process, which aims to ensure end customers can retain service when their CP has encountered financial difficulties. Under this process 3 outbound call attempts are made to end users to advise them that an alternate supplier is required if they wish to retain their end service. These outbound calls have proved ineffective, so a new process will be introduced where an Openreach letter will be sent.

Openreach has notified its first six exchanges where the copper charge control will be withdrawn. This occurs when FTTP coverage reaches 100%, with some exceptions. This will mean the Ofcom charge control would fall away, although the ‘reasonable pricing’ obligations will remain, however, there is a 12-month notification period and it cannot become effective earlier than 24-months from the notification of Stop-Sell.  

All-IP Steering Group

Openreach deployed its UK WLR Stop Sell in September 2023 with limited exemptions, permitting orders of WLR lines in scenarios where the equivalent All-IP product or product variant were either not yet available, or not fully consumed across the supply chain. These exemptions were removed in March 2025. Industry will however be able to place WLR3 orders in exceptional circumstances to support CNI and vulnerable customers. However, Openreach plan to withdraw these exceptions during 2025. Openreach received some late industry feedback which affected the timetable, but this will be formally briefed out shortly.

There are approximately 3.4m WLR lines remaining, with a run rate of reductions of 44k per week. A run rate of circa 50k per week is required to reach zero by January 2027. With both PDPL (SOTAP) and prove Telecare now being made available, Openreach consider it has provided all of the migration journeys to allow CPs to progress with migrating their customer PSTN bases.

Feedback from discussions with CPs has identified industry concern and some level of confusion regarding how to deal with situations where a customer’s WLR line/voice are supplied by one CP with their broadband provided by another. The general consensus of discussion with industry is that while these split CP cohorts are complex and more difficult to manage, it is not clear that Openreach can do anything to assist.

Prove Telecare has now launched which will now allow this significant cohort of vulnerable customers to be addressed.

OTA2 voiced some concerns regarding both Industry and Openreach understanding of the complexity of the migration task for the remaining businesses on WLR. Collaborative work is ongoing to better understand and address this, with Openreach formulating how better to raise awareness amongst business customers of the need to exit analogue products by January 2027.

Customer Switching

The OTS process is now firmly established amongst the majority of retail CPs with residential customers switching NBICS (Number Based Interpersonal Communications Service – fixed Voice) and IAS (Internet Access Service – fixed broadband), with TOTSCo reporting over 1.8million successful OTS order trigger events completing since launch.   OTA2 continue to co-chair the OTS-IPG (Industry Process Group) who work to look at improvements in CP consumption and compliance to the OTS process, along with identifying additional guidance for some of the more unusual and unexpected exceptions that the volume of switching customers occasionally throws up (with ~2million messages each month the volumes are producing a very low number of such instances).  

The TETP (Tactical Erroneous Transfer Process) remains available to all registered CPs and supports collaboration between gaining and losing CPs to resolve suspected Erroneous Transfers before a customer is impacted. All TETP documents can be found on the OTA2 website, under Best Practice Guidance – Consumer Switching, including the registration template for any CP wishing to join, along with OTA2 published Best Practice guides to aid successful switching, avoiding some of the more common causes of issues. OTA2 are aware of a small number of erroneous transfers being intercepted by the TETP process, and for that reason are continuing to support new registrations should CPs wish to be included. The TETP process includes a recording template for CPs to log TETP incidents, and how important that evidential data will be, if CPs wish to more formally pursue persistent issues with erroneous transfers.

OTS Porting

The OTS Porting Focus group (chaired by OTA2) will be holding a further series of sessions in the coming months, both for those CPs already developing solutions to deploy OTS Porting for their switching solutions and for CPs who plan to offer the OTS Porting capability to their channel partners, who are asking for this capability.

Both groups will be focusing on plans to move into their test environments, then a phased deployment into live architectures ahead of co-ordinated test regimes with partner CPs (supporting both simple and subsequent port scenarios. The objective of delivering significant system architecture developments into live in early 2026 remains, and OTA2 will be working with CPs throughout this period.             

Business Switching

A reminder that all of the up-issued, and now under full change control, documents associated with the Switching for Business process and  message specifications can be found on the Gaining Provider Led Business Switching public - FCS website. These documents can be accessed without any need for registration.

The GPLB-SG (Gaining Provider Led Business – Steering Group – co-chaired by OTA2) will shortly be issuing a newsletter with more details about documentation and other information. The GPLB-IPG (Industry Process Group) is continuing to produce and publish a number of Best Practice Guides designed to assist CPs in effectively using the ‘Switching for Business’ process and establishing a common understanding of how the interaction of Gaining and Losing CPs in the switching journey for business customers will work.      

The GPLB-SG and IPG continue working closely with both TOTSCo and the MAP (Managed Access Provider) community to ensure a solid understanding of the process is in place.      

Number Porting

The NPESG (Number Porting Executive Steering Group) and NPPCG (Number Porting Product and Commercial Group) remain very active and focused on the many challenges facing the porting community at this time. Whilst progress is being made on several fronts, including the rapid move to an All-IP environment and the urgent work to address the UK Government's demand to reduce telephone fraud, it is increasingly acknowledged that a more significant restructuring of the processes supporting fixed line numbering in the UK should be considered. Such an undertaking will not be without cost to the industry, and at a time when focus is on more immediate issues, not least those already highlighted in this article, it is difficult for industry to prioritise the funding and resourcing of the investigations and developments to overcome two decades of inertia. However, as a first step towards an eventual re-design effort, OTA2 have offered to work with industry to create a record of requirements to enhance the porting process, so that these can form part of a larger ‘use case’ database that can drive the long-overdue uplift in UK Number Porting when it happens.

On a day-to-day level the Porting community continue to see issues with wholesale and singleton transfer scenarios, which do not fall under Porting or Switching regulation, so cannot be resolved by the business-as-usual porting processes. Industry have created a Best Practice Guide for these scenarios, however this does rely on the spirit of reciprocity between the Voice Service Providers involved (more can be found in the Number Porting Core Processes section of the OTA2 hosted Best Practice Guides).

OTA2 would also like to remind CPs that we are quickly approaching the festive period and that the now traditional Christmas ‘Number Porting opening hours’ schedule is being collated by OTA2 and will be distributed to CPs registered on the OTA2’s NPESG and NPPCG lists. Whilst on that subject, OTA2 have also initiated a review of those distribution lists, to ensure they remain up-to-date and include the appropriate contact details – individuals on those lists should please look out for an email soon.  

Service Levels

Copper and Fibre provision

Openreach FAD (First Available Appointment Date) performance nationally, over the 5-day period ending 29 October 2025 was as follows:  

Notes:

1. MI and SI are Managed-Install and Self-Install orders
2. FTTC is Fibre to the cabinet
3. FTTP is Fibre to the premises
4. SOGEA is Single Order Generic Ethernet Access
5. GFAST is Fibre-base Ultrafast Broadband

Copper repair

LLU and WLR ‘on time repair’ performance has seen a downward trend for LLU but slightly upward for WLR, achieving a 4-week rolling average of 80.1% and 79.5% respectively, by week ending 31 October 2025.

*The figures quoted exclude BT downstream connections