Paper billing for vulnerable customers, not universally: CRTC

The CRTC has determined that all communications service providers (CSPs), including telecommunications service providers (TSPs), Canadian carriers, and broadcasting distribution undertakings (BDUs), must provide certain market segments with free paper billing, in an effort to protect vulnerable consumers. In a Thursday press release and decision released concurrently, the CRTC stated that customers who self-identify as persons with disabilities, customers without home internet access or mobile data services, and seniors (using the government's age of 65) will be able to receive paper bills, at no charge, and upon request. The new rules apply to telecommunications service providers immediately. The CRTC found that a universal obligation that paper bills be provided would reduce adaptability to technological change, add to regulatory burden, and would be counterintuitive for competition as it would restrict the ability of CSPs to differentiate their billing services. “There are still many Canadians who have legitimate needs to receive their bills in paper format. This decision strikes a good balance between allowing providers to encourage their customers to switch to digital billing and ensuring Canadians are treated in an inclusive and accommodating manner. We expect all providers subject to these new rules to swiftly make the necessary changes,” CRTC chair and CEO, Ian Scott, stated in the release. BCE Inc., Bragg Communications Inc.'s Eastlink, Cogeco Inc., Quebecor Inc.'s Videotron, Rogers Communications Inc., Saskatchewan Telecommunications Holding Corp., Shaw Communications Inc., Tbaytel Inc., Telus Corp., TekSavvy Solutions Inc., and Xplornet Communications Inc. are all ordered to report to the commission by May 11 indicating how they have relayed this information to their customers, including scripts and training materials for their customer service representatives and information on their websites. Back in 2014, debate about the issue surfaced when companies started levying extra fees for paper statements. In response, the government passed legislation forbidding telecom companies from charging customers to receive physical bills. Then the lead up to Thursday’s decision began in June 2018 when the Public Interest Advocacy Centre (PIAC) filed a Part 1 with the regulator claiming that the intent of the 2014 decision was to ensure subscribers could access paper copies at no charge, yet companies such as Telus’ Koodo discontinued paper billing and began charging customers $5 to receive a physical copy upon request. The regulator rejected PIAC’s request almost two years later, but launched a consultation in response to a number of complaints about online bill payments. At the same time Rogers announced it was also doing away with its paper option. In June 2020, PIAC asked the government in a petition to the governor-in-council to either rescind the decision, or send it back to the CRTC for further consideration. Its request was denied in March 2021. In their 2020 submissions to the CRTC’s consultation, telecom companies and broadcasters overwhelmingly urged the CRTC not to intervene in billing practices, arguing billing formats act as “competitive differentiators,” while the majority of public submissions called for the CRTC to require telecoms to provide paper bills on request. TekSavvy was the only telecom who supported a mandate to provide paper bills but asked that it be confined to “dominant service providers.” PIAC and the National Pensioners Federation (NPF), in a joint submission, further argued that not all customers, especially seniors, were comfortable with electronic billing methods. The CRTC found in its Thursday decision that offering paper bills can be seen as a natural competitive incentive and, therefore, it is unnecessary to mandate free paper billing. “One provider’s refusal to cater to such a demand can be another provider’s opportunity to gain a customer. In fact, there are competitive options in the marketplace, and many CSPs provide paper bills such that consumers would be able to select a service provider that provides paper bills if they choose,” it wrote, noting that many dominant companies indicated that they intend to migrate to e-billing as a default. “Further, given the options available in the market, it is not clear that a universal mandate to provide paper bills is required to respond to consumer interests... Not even individuals and consumer advocacy groups on the record of this proceeding were entirely in support of such a measure.” The CRTC did determine, however, that supporting vulnerable customers is in line with its previous regulatory policies and there was evidence on the record to show that some customers who need paper bills are not able to receive them. The CRTC concluded that the evidence indicated that it could not rely on market forces to meet the needs of customers and it was appropriate for the regulator to intervene. The commission has already imposed regulatory obligations for telecommunications companies to provide certain groups with disabilities – such as customers with visual disabilities – with alternative billing formats. However, the commission found in the record of its proceeding that there are “additional accessibility issues experienced by customers with other types of disabilities,” such as cognitive disabilities, which can be addressed by mandated paper bills. The commission then found it was appropriate to include people without access to home internet or mobile wireless data services, as there are “serious” consumer privacy and security concerns over accessing bills through public internet or through other means. Finally, the commission determined that although data shows that seniors are increasingly accessing the internet, the figures also show that internet-usage for the age group is still well below that of others. “For the three identified groups of customers, migration may present a significant barrier to their ability to access their billing statements, review the charges, and pay their bills. As a result, there is a higher likelihood for error in payments, missed payments, late payment charges, or possibly disconnection as a result of inadvertent non-payment,’ the commission wrote in its decision. According to the decision, TSPs, including Canadian carriers, must make the information regarding accessing paper bills “easily available” in the billing information or frequently asked questions sections of their websites, in their account management systems, and through their customer service representatives. They must also train customer service representatives on how to answer inquiries on paper bills, inform any new subscribers whether paper bills are limited to certain groups of customers, including those mandated by the CRTC, and they must receive verbal or written consent before transitioning customers who do not subscribe to internet or mobile data services to electronic billing. Broadcasters must adhere to all the same requirements, as the CRTC “intends to impose conditions of licence to this effect at the next opportunity.” The commission will also revise the exemption order for smaller BDUs. – Reporting by Jenna Cocullo at jcocullo@thewirereport.ca and editing by Michael Lee-Murphy at mleemurphy@thewirereport.ca

Paper billing for vulnerable customers, not universally: CRTC

News | February 10, 2022

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Paper billing for vulnerable customers, not universally: CRTC

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