CRTC warned to avoid lengthy notices, costly changes in consult on end-of-contract notifications

After launching multiple consultations on improving customer protection measures and increasing flexibility for people choosing their mobile and internet services, the CRTC has received a round of interventions including from industry players and advocacy groups on improving the notices people get as their contracts come to an end. In addition to its review of the notices, the CRTC is considering in separate consultations banning telecom service providers (TSPs) from charging cancellation fees meant to discourage customers from changing their plan, and requiring TSPs to offer self-service mechanisms. Amendments made to the Telecommunications Act, contained in the federal budget and signed into law earlier this year, require the CRTC to implement such consumer protection rules. The regulator is also looking into how to make it easier for people to shop around for home internet services. Of the four proceedings, interventions have only come due so far in the call for interventions on improving the notices people receive about the options available to them as their contracts with service providers expire. The others have deadlines into late February and mid-March. In this particular proceeding, the commission was seeking comments on how to improve the quality of information people get from their wireless and internet service providers when their contracts are about to end – including information about other service plans that might meet their needs, when their promotional pricing ends, and the information Canadians get when roaming internationally to inform them of alternatives that might suit their needs. Specific to the 90-day notices received by customers as their contracts come to a close, the regulator said in December that it was of the preliminary view that people should be told: -- What the total “all-in” price of service would be, broken down into one-time fees and monthly fees including taxes; -- The services included in the contract like voice, text, data, and any service limits; -- Mobile network coverage and network speeds for mobile and internet services. “The commission is also of the preliminary view that providing Canadians with a list of all telecommunications service plans offered by their service provider is not effective,” the regulator said. “Rather, it would be more helpful for Canadians to be informed about plans offered by their current provider that best align with their existing level of service to ensure that they can choose a plan that best meets their needs and to avoid being oversold plans they do not want.” Telecoms concerned by costs, other changes The Canadian Telecommunications Association (CTA) said in an intervention to the proceeding made public Monday, Feb. 17 that requiring the 90-day notice to include information on existing in-market plans that “best align with the customer’s current level of service is impractical and does not reflect customers’ evolving needs.” The association, whose members include BCE Inc. and Rogers Communications Inc., in addition to several other smaller telecoms, said that making recommendations on current service levels could lead people to choose “suboptimal plans.” “The dynamic and competitive nature of the telecom market means that plans change frequently. Plan information sent 90 days before the end of a contract may become outdated by the end of term, causing confusion and dissatisfaction among customers,” the CTA said. The group also noted that the 90-day notice as it currently exists “contains a lot of information.” It instead proposes including information in the notice on how people can find more details about the latest plans. “This allows customers to choose the best plan for their current or future needs when they become eligible to change plans. This can be done by directing customers to the service provider’s product website, retail store, or customer care telephone line or other contact methods,” it said. It additionally raised concerns that by giving people too much information, they could become overwhelmed. “While a requirement to provide additional information in the 90-day notice may be well intended, there is the risk that customers will be overloaded by too much information, causing confusion and resulting in customer disengagement and dissatisfaction,” it said. It is necessary for the process to be “efficient and effective,” the CTA said. “This objective is especially important given the current economic realities for Canada and the telecom sector,” the group said, noting companies are up against decreasing prices, high borrowing costs, higher network costs, increased competition from multinational players, lower immigration, and climate related risks as “just a few of the headwinds that telecom providers face.” “At a macro-level, the threat of U.S. tariffs and other economic measures pose challenges to Canada’s economic stability and growth prospects. Even if the suspension of U.S. tariffs is extended beyond the current thirty-day reprieve, the economic uncertainties caused by an unpredictable U.S. government will remain for the foreseeable future,” it anticipates. “These measures and uncertainties are likely to have significant impacts on consumer confidence and purchasing power, which could have an impact on service providers. A weaker Canadian dollar will also negatively impact service providers who purchase telecom equipment and devices in U.S. dollars.” The CTA argues that the commission should be focused on finding ways to “reduce and avoid creating” any new regulations that cause incremental increases in costs that are not in balance with the benefit to consumers. “These additional costs would ultimately have to be recovered through service fees charged to consumers, which runs counter to the Telecommunications Act’s policy objectives of rendering affordable services and recognizing the economic and social requirements of consumers,” it said. In an intervention of its own, Bell agrees with the CTA that avoiding confusion is key, as is avoiding an increase in costs for companies and consumers. “The commission should avoid overly prescriptive outcomes that increase complexity for customers or impede the continued development of innovative customer-first processes, increase operating costs for service providers, and risk disrupting the dynamic competition taking place in the market today,” Bell said. The company argues that requiring that recommendations be made in the notice for in-market plans “would not be appropriate or even helpful to consumers.” Instead, the telecom asserts that it would “mislead or confuse them.” Bell agreed with the CTA that consumers can be directed from the notice to other areas to find the information they need, such as Bell’s online site and customers’ self-serve profiles, rather than information on available plans being included directly in the notice. “This approach recognizes that delivering the most appropriate offer to a customer at any given moment presents both accuracy and suitability challenges given fluidity in the marketplace, while preserving consumer choice by ensuring customers are aware of their choices and where to obtain accurate information about the best options available to them at the time they decide to change their arrangement,” Bell said. For its part, Rogers argues it should not be assumed that customers only want or need to be notified about plans that are similar to their expiring agreements. “The commission’s proposal to focus information on plans that best align with a customers’ ‘existing level of service’ presumes that a customer’s needs and wants do not change over the life of a fixed-term contract,” Rogers said, adding that it “undermines customer freedom of choice and jeopardizes the growth of the sector.” Telus Corp. argues that the proposed changes to the notices and them including suggestions of other service plans could end up making for a worse deal for some customers, saying solely including in-market pricing on plans based on a customer’s existing level of service could block for them the benefit of receiving more tailored and potentially better-value offers. The company said that the changes to the notice, as proposed, “could actually be worse for customers because it “fails to account for the fact that many renewing customers are eligible for rates that are often lower than publicly advertised in-market plans.” Telus pitches instead that the notice could include “current plans offered that are relevant to the customer,” taking customers’ “actual usage patterns, including overages,” into account. “... this approach aligns with the goal of empowering consumers to make informed decisions,” Telus said. The Commission for Complaints for Telecom-television Services (CCTS) suggested to the CRTC that 90-day notices could include information about where customers can find their historical usage information so they can avoid being oversold on plans with services above and beyond their actual needs, or undersold on plans that land them with unexpected additional usage charges. The Public Interest Advocacy Centre (PIAC) agrees that consumer usage habits could be taken into account in providing people with information on other plans in the notices, suggesting that the information be based on a defined period prior to the end of the contract, such as the 90 days before the notice is sent to a consumer. “This would mean that providers would not only be providing information on ‘bigger’ plans, but perhaps also ‘smaller’ plans that more appropriately suit the needs of the consumer,” the group said. Avoid lengthy notices, caution watchdogs With the proposed changes to the 90-day notices, the CCTS warned the CRTC of the need to balance the benefits of providing people with information with the volume of information included in the notice. “For example, providing details of complex wireless device financing options in the 90-day notice might reduce the effectiveness of the notice,” it said. Canada’s Competition Bureau agrees that the notices need to be formatted appropriately. “The medium matters. Even the best, most clearly worded information will still not be helpful if it is buried in a place where customers cannot or will not see it, like at the bottom of an invoice or in tiny fine print,” the bureau said. “A message will not be effective if it is communicated in a way that is hard to understand, or through a medium that people do not use or typically ignore.” The bureau said the CRTC should “take a flexible approach” in its guidelines that establish baseline expectations “while leaving the door open for providers to leverage their own insights about how to best communicate given their customers’ distinct preferences. “For people who use an account app, the CRTC could require providers to notify customers when they log in to their account in the months before contract expiry, for example. And for people who do not use the app, providers could text or be required to identify other means which are most salient for the customers’ communication preferences,” the bureau said. CRTC considering interventions in four consultations in conjunction with one another The CRTC announced Friday, Feb. 14 that as it works through four different proceedings on improving how people manage their cellphone and internet service plans and how they shop for home internet services, it will consider the interventions of the other, similar proceedings as applicable. “The commission wishes to ensure that all relevant interventions received from the public are duly considered in this proceeding,” it said in announcements about each of the four cases. Commission spokesperson Mirabella Salem confirmed to The Wire Report in an email Tuesday afternoon that the proceedings will continue on separate tracks and not be consolidated. “Each of the proceedings focus on distinct issues that are not directly related to each other, and so they are continuing as separate proceedings. We have noticed, however, that a small number of interventions include comments in one proceeding that may relate to one of the others. We have taken this step to simplify the process for Canadians and make it more convenient for them to submit their comments.” hdaley@thewirereport.ca With files from Phalen Tynes-MacDonald

CRTC warned to avoid lengthy notices, costly changes in consult on end-of-contract notifications

Regulatory |
By Hannah Daley
| February 18, 2025

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CRTC warned to avoid lengthy notices, costly changes in consult on end-of-contract notifications

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