BT’s compliance assurances for certain migration to IP processes

BT commits to stronger protections for vulnerable customers during the digital phone switchover.

Ofcom has secured improvements from BT to strengthen its protections for telecare customers during the migration from analogue to digital landlines. 

Protecting vulnerable customers is a priority for Ofcom. We have been clear in our expectations for telecoms providers during the migration process: they must identify, protect and support vulnerable customers, and ensure that migrations are underpinned by effective safeguards.  

What we did 

As we move into the final stages of Openreach’s PSTN switch-off, it is crucial that telecare customers continue to be safely supported through every stage of migration. For this reason, we have been closely monitoring the steps taken by telecoms providers to protect vulnerable customers during the migration, including telecare users. 

Through our monitoring programme, we identified initial concerns with an outbound calling campaign that forms part of BT’s broader migration programme. In our view, there were areas where BT’s processes for this campaign were not sufficiently robust and could have placed telecare users at risk. These included the potential for agent error when checking the telecare status of customers ahead of migration, delays or possible inconsistencies in the processes for reconnecting telecare customers who experience a loss of service, and possible gaps in BT’s published vulnerability policy.

Reflecting the nature and scope of the issues identified the company entered into a period of compliance remediation in February 2026 to remedy our initial concerns. This is a process where we seek to resolve an issue without the need for formal enforcement action.

Our intervention aimed to provide targeted, timely and effective remedies to the issues identified, and complements our ongoing industry-wide monitoring programme for IP migration. BT engaged constructively on these matters, introducing iterative changes over several months to address our concerns as follows:

BT’s further improvements for the protection of vulnerable customers

1. Introducing further safeguards to better verify migrating telecare customers before orders are progressed. This includes additional system alerts and improved agent training to ensure greater consistency of agent behaviour.
2. Strengthening welfare restoration processes for vulnerable customers, ensuring that support is provided consistently and without unnecessary delay. These include:
   a. incorporating new system alerts to prompt agents where internal escalation and restoration of service for vulnerable customers are required;
   b. strengthening post-migration checks for telecare customers;
   c. introducing new measures to support proactive review and (where necessary) escalation where there has been a fault on a customer’s line; and
   d. refreshing and delivering improved agent training. 
3. Reviewing and updating BT’s published vulnerability policy to provide greater clarity on how the impact and effectiveness of its policies and procedures for vulnerable customers are monitored and evaluated. 

Ofcom considers that these changes sufficiently address the concerns we identified and secure meaningful additional protections for vulnerable customers. We think this is important to improve the protections for consumers in the final stages of Openreach’s PSTN switch-off, but also for future telecoms modernisations programmes.  

BT’s agreement to make improvements, or Ofcom’s acceptance of these, does not constitute a finding of non-compliance. Ofcom has not made any determination as to whether BT has contravened any regulatory requirement. 

Next steps

BT has already implemented the majority of these measures, with final systems and policy changes to be implemented by the end of November. We will closely monitor BT's progress, including the effectiveness of the measures introduced. We will also continue to scrutinise BT's and other providers’ migration activities through our monitoring programme and will not hesitate to take further action if new issues emerge.