Telecom Commission Letter Addressed to Stephen Schmidt (Telus)

Ottawa, 22 August 2018

Our reference: 8661-P8-201804295


Stephen Schmidt
Vice-President - Telecom Policy & Chief Regulatory Legal Counsel Telecom Policy & Regulatory Affairs

Re: Request for Information re: Part 1 Application by Public Interest Advocacy Centre (PIAC) and National Pensioners Federation (NPF) regarding paper billing by Koodo Mobile

Dear Mr. Schmidt,

On 4 June 2018, PIAC submitted an application under the Telecommunications Act and pursuant to Part 1 the CRTC Rules of Practice and ProcedureFootnote1 regarding paper billing by Koodo Mobile. According to complaints received by PIAC-NPF from consumers and those posted in online forums, Koodo Mobile discontinued paper billing.

Commission staff has reviewed the application, interventions and reply, and considers that additional information is required on the record of the proceeding.

Q1. TELUS Communications Inc. (“TELUS”) intervention stated that Koodo Mobile provides paper bills at no charge to many customers, including those with accessibility needs.

Commission staff is aware that on 28 August 2014, certain telecommunications service providers, including TELUS, met with the Commission’s Vice-Chairperson of Broadcasting and the Vice-Chairperson of Telecommunications and committed to exempting the following customers from fees for paper bills:

  1. Please advise how many Koodo Mobile clients are currently receiving bills in a paper format and what percentage (%) of the customer base this represents.
  2. TELUS’ intervention states that Koodo subscribers have access to their bills free of charge, even if they have no access to home or mobile internet and that the data required to access online bills are zero-rated, including for customers whose rate plans do not include data. Please advise if all Koodo subscribers have mobile phones that are capable of accessing Koodo’s online portal. If not, please advise if Koodo provides paper bills to these customers. 
  3. With respect to customers with accessibility needs, does Koodo limit the provision of paper bills to persons who are blind or partially sighted or does it also provide paper bills, upon request, to persons with other disabilities, such as persons with intellectual or cognitive disabilities, who may have challenges with accessing bills in an online format? If Koodo does not provide paper bills for other persons with disabilities, please explain why not.
  4. Does Koodo’s online customer portal meet the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG) 2.0 standards?
  5. Are customers under the following groups eligible to receive paper bills:
    • seniors aged 65 and over; or
    • veterans of the Canadian Armed Forces?
  6. In what other circumstances does Koodo provide paper bills on demand?

Q2. In its application, PIAC stated that a Koodo Mobile customer may obtain a paper bill by requesting a “bill copy”, to which a $5/bill charge applies. Is this Koodo’s policy and, if so, explain how it is consistent with section 27(2) of the Telecommunications Act which states that any person who provides telecommunications services shall not charge a subscriber for providing the subscriber with a paper bill.

Q3.TELUS’s intervention states that over the last 12 months, Koodo has taken steps to migrate some (but not all) customers who were receiving paper bills to an electronic billing system.

  1. Describe the steps taken to inform existing customers about the migration.
  2. Prior to the migration, what percentage of customers were receiving paper bills?
  3. Were existing customers given the opportunity to opt out of being migrated to electronic billing?
  4. Are new customers given the opportunity to opt for paper or electronic billing? If not, are they informed at the time of purchase that paper bills are not an option, except in specific circumstances?

Responses to the request for information are to be filed with the Commission, and served on all parties to this proceeding by 12 September 2018. All submissions are to be received, and not merely sent, by that date. Any party to this proceeding may file comments on the responses by no later than 21 September 2018.

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

If you have any questions, please contact Patrick Arseneau, Senior Analyst, Social and Consumer Policy, at 819 994-7993 or


Original signed by

Nanao Kachi
Director, Social and Consumer Policy
Consumer Affairs and Strategic Policy 

c.c.: Vitali Berditchevski, TELUS,
John Lawford, PIAC, 
Philippe Gauvin, BELL,
Christopher Hickey, CNOC,
Patrick Arseneau, CRTC,

Date modified: