Submitted: The Two Sides Team October 24, 2013

You by now probably have noticed that something interesting is taking place in Ireland. Yes. That's it. Ireland has a fierce consumer protection approach lead by ComReg against providers charging their clients for paper bills.

E-Invoicing Platform – 29 October 2013

You by now probably have noticed that something interesting is taking place in Ireland. Yes. That's it. Ireland has a fierce consumer protection approach lead by ComReg against providers charging their clients for paper bills.

Until recently, there was some divergence in Ireland between service providers who provide consumers with paper bills and those who have migrated their customers onto electronic bills (e-bills or online bills). This led to different levels of consumer protection.

However, new conditions were introduced by ComReg on 6 June 2013 (ComReg Document 13/52). All providers offering pre-paid and/or post-paid services will need to familiarise themselves with the new requirements and ensure they can comply by the end of the transitional period (further details below). The conditions came into effect at the beginning of August 2013.

Summary of the first e-billing consumer protection regulation ever

So what does this first implicate? Well, in summary:

1. Bills for post-paid customers must be provided free of charge
This applies in respect of a fully itemised bill or a non-itemised bill, in line with the customer's preference.

2. Pre-paid customers must be able to require a transaction history (including usage and charges) free of charge.

3. The post-paid customer's explicit consent is required to change the level of bill itemisation. Calls which are normally free of charge should not be identified/itemised however, for either post-paid or pre-paid customers.

4. Customers who are asked to switch from paper bills to e-bills are give a one month advance notice and are allowed to withdraw from his/her contract free of charge if he/she does not wish to be moved to e-billing.

5. Service providers currently providing paper bills may migrate customers to alternative billing mediums (eg, e-bills) provided that they can ensure and verify the customer can access the alternative medium.

6. When using online bills, an alert must be sent to notify the customer that a bill is available; the alert should be sent during appropriate, socialable- hours;

7. Consumers who do not want to receive alerts must be able to opt-out.

8. The changes apply purely in respect to bills for 'consumers', meaning business customers are not affected. 

Consequences for Irish Telecom Providers

So what does this mean for Irish telecom providers:

1. Service providers will be offered a transitional period of up to six months to fully comply with all the amended conditions set out in the amended General Authorisation.

2. Service providers should take stock of their current billing practices to consumers, and identify any changes needed to comply with the new conditions (which might include a roadmap to achieve compliance), not least given the financial consequences that attach to breach of a condition of their General Authorisation.

3. Service providers should note that existing regulatory obligations concerning proposed changes to a customer's terms and conditions continue to apply. This means that any provider wishing to move customers from paper bills to e-bills needs to give the requisite one month advance notice and allow the customer to withdraw from his/her contract free of charge if he/she does not wish to be moved to e-billing.

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