PhonepayPlus Forum – A Report

Yesterday PhonepayPlus (PpP) held its quarterly Forum to report back on industry developments and to start garnering views on its proposed 12^th Edition of the Code of Practice. It was a good, productive Forum and the PpP proposals sparked considerable and positive debate. I sensed a real desire from both PpP and the industry to consider significant changes to the way paid for services are regulated.

There are four main changes set out in the PpP discussion paper:

• That the new Code could be a more goal based rather than being overly prescriptive
• That more than one company in the value chain will assume an appropriate degree of responsibility for the provision of compliant services
• That there could be the creation of a database on which all service providers and information providers will be registered for due diligence and risk management purposes
• That providers must have in place adequate customer care facilities to ensure consumers are able to register a complaint and seek redress.

None of these proposals are quick and easy wins but then nothing worthwhile is ever easy. They will require significant consideration and thought on how the proposals will apply in practice. For example, having a more goal based Code is certainly easier to manage in the fast changing mobile media industry. However, many service providers want absolute confidence that services are complying with the Code and this can only really be achieved by prescribing exactly what needs to be done and by which party in both the advertising and operation of a phone paid service.

I welcome the opportunity to work with both the regulator and our members on how responsibility for compliance can practically be applied to the culpable parties. This has long been a source of contention – aggregators are often found in breach of the Code for services and advertising they are not responsible for. In practice this challenge is going to be difficult. It will require careful planning and possible wholesale changes to the way cases are investigated, reported on and appealed. It could increase regulatory costs and the length of time to investigate a case to a successful conclusion. However, it is of fundamental importance that the culpable parties are held accountable so I relish the opportunity to work with our members to ensure processes are put in place that deliver on these promises.

It was a positive Forum and I look forward to ensuring that the regulatory regime moving forwards is good for the industry, the regulators and, of course, the consumers.

MEF is holding its meeting on the Scope review on Friday 10^th July from 9am to 12.00 to discuss the Ofcom Scope Review which will have a direct impact on the PpP consultation. Soon after, we will host a meeting on the PpP discussion document.

For further information, please contact me.

- Suhail Bhat, Policy & Initiatives Director, MEF