Telecom - Staff Letter addressed to the Distribution List

Gatineau, 14 March 2025

Reference(s): 1011-NOC2016-0293

BY EMAIL

Distribution List

Subject: Wireless Code– 2025 Compliance Reports

Dear Wireless Service Provider,

Appendix 1 of this letter sets out the questions you are to answer in your 2025 annual Wireless Code compliance report, due by 30 April 2025.

Context

In Review of the Wireless Code, Telecom Regulatory Policy CRTC 2017-200, 15 June 2017, (the Policy), the Commission made targeted changes to and clarified existing rules of the Wireless Code (the Code).

The Code is a mandatory code of conduct for providers of retail mobile wireless voice and data services (wireless services) to individual and small business customers in Canada. The revised Code is set out in Appendix 1 of the Policy.

In the Policy, the Commission directed wireless service providers (WSPs) “to submit compliance reports on an annual basis, by 31 March of each year, to support the Commission’s role in monitoring WSPs for systemic non-compliance and enforcing the Code” (the Wireless Code compliance reports).

This letter sets out questions that all WSPs must answer when submitting their 2025 Wireless Code compliance reports. Companies that operate flanker brands must file responses on behalf of these brands in addition to their primary brands. A flanker brand, also referred to as an extension or a secondary brand, is expressed as logos or words, and is used by the primary brand WSP to market and offer varying services and plans to consumers. The primary brand’s network is used to provide services under the flanker brand. Virgin, Koodo, and Fido are examples of flanker brands. A primary brand is the brand that is most recognizable by consumers and is directly associated to the parent company that owns and operates the facilities to provide services.

Procedures for filing

As set out in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, WSPs may designate certain information as confidential.

WSPs must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

The Commission requires that you submit your documents electronically by using the secured service "My CRTC Account" (Partner Log In or GC Key). On this web page, you will also find a link to information on the submission of applications to the Commission “Submitting applications and other documents to the CRTC using My CRTC Account.”

Please file your response to this letter no later than 30 April 2025 and:

• ensure that it is addressed to: Nanao Kachi / Consumer, Analytics and Strategy, and
• include file number 1011-NOC2016-0293.

Yours sincerely,

Nanao Kachi
Director, Social and Consumer Policy

Distribution list

bell.regulatory@bell.ca;
geoff@brooketel.ca;
Regulatory@brucetelecom.com;
Regulatory.Matters@corp.eastlink.ca;
martha.facey@execulink.com;
a.lawrence@hay.net;
ryan.mcclinchey@hurontel.on.ca;
regulatory@icewireless.com;
regulatory@iristel.com;
knaylor@mornington.ca;
lhallahan@mornington.ca;
regulatory@quadro.net;
regaffairs@quebecor.com;
melanie.cardin@quebecor.com;
rwi_gr@rci.rogers.com;
document.control@sasktel.com;
regulatory@sjrb.ca;
richard.biron@sogetel.com;
stephen.scofich@tbaytel.com;
regulatory@tccmail.ca;
regulatory.affairs@telus.com;
reglementa@telebec.com;
regulatory@corporate.wightman.ca;
Xplornet.Legal@corp.xplornet.com;
carl.macquarrie@corp.xplornet.com;
harleen.sawhney@zoomermedia.ca;
scott_laird@ztarmobile.com  

Appendix 1 - Questions for all WSPs

Q1. Formal complaints and CCTS

In paragraph 426 of the Telecom Regulatory Policy CRTC 2017-200 (the Policy), the Commission directed all wireless service providers (WSPs) to “inform customers of their right of recourse to the [Commission for Complaints for Telecom-Television Services (CCTS)] immediately upon a failure to resolve a complaint at the second level of escalation, and again at subsequent levels of escalation within the WSP’s internal process; and retain statistics on an ongoing basis on how many customers, out of the total number of customers who make a formal complaint, they informed about the CCTS, and provide these statistics to the Commission as part of the compliance reporting process on an annual basis.” (Emphasis added)

For the period from 1 January to 31 December 2024, provide the following information, reporting separately for each of your brands.

1. How you define “formal complaint”, including an explanation of where a formal complaint fits into the overall complaint escalation process and example of a formal complaint.
2. The number of individual and small business customers that made a formal complaint about their retail mobile wireless service.
3. The number of customers that made a formal complaint that were provided with information about the CCTS during the complaint process.

Q2. Significant changes since last report

Have there been any significant changes since your last report in terms of either how you comply with specific rules or your compliance with specific rules? Significant changes in how you comply could include, but are not limited to, changes to content or format of standard contracts, changes to the content of notifications provided to customers, changes in how you train customer service representatives about the Wireless Code (the Code), etc. Examples of changes in compliance could include instances where a provider self-identified in 2018 as not meeting certain requirements but considers that it is meeting them now, or vice-versa.

If so, please provide a detailed explanation of the changes.

Q3. Self-identification of ongoing compliance

Fill out the following table in full to confirm whether you consider that you are currently in compliance with each requirement set out in the revised Wireless Code.

Q4. Postpaid services

If you provide postpaid wireless services, provide a copy of the documents you provide to customers entering into new postpaid contracts.

This should include the following:

1. A copy of an example contract;
2. A critical information summary (CIS) for that contract;
3. Other related documents that would generally apply to a postpaid contract, including terms of service, fair use policies, and privacy policies;
4. As applicable: if the contracts, CIS, and other related documents you provide differ depending on whether the customer has selected a multi-user plan( A contract for wireless services in which an account holder pays for the wireless services of at least two device users, regardless of whether the account holder is also a device user (also known as a shared plan or family plan)) or an individual plan, provide copies of items a-c above for both; and
5. As applicable: if there have been significant changes to your standard contracts and related documents since your last compliance report, provide an overview of the changes.

Q5. Prepaid services

If you provide prepaid wireless services, provide a copy of the documents you provide to customers entering into new prepaid contracts. This should include the following:

1. A copy of an example contract; and
2. Other related documents that apply to the contract, including terms of service, fair use policies, and privacy policies.
3. As applicable: if you offer prepaid cards, please provide a copy of the information or terms of service provided to the customer in association with that prepaid card.
4. As applicable: if there have been significant changes to your standard contracts, related documents or prepaid cards since your last compliance report, provide an overview of the changes.

Q6. Notifications and consent

Provide an example of the text used and describe the delivery method(s) you use when

1. seeking consent from the account holder or an authorized user to change a key term or condition of a customer’s postpaid contract;
2. seeking consent from the account holder or an authorized user to pay additional charges beyond the $100 of national and international data roaming charges within a single billing cycle;
3. seeking consent from an account holder or an authorized user to pay additional charges beyond the $50 in data overage charges within a single billing cycle;
4. notifying the account holder and the device user when a device is roaming in another country; and
5. notifying a customer on a fixed-term contract at least 90 calendar days before the end of their initial commitment period whether or not the contract will be automatically extended.

If there have been significant changes to how you obtain customer consent from the account holder or an authorized user since your last compliance report, provide an overview of the changes.

Q7. Promotion of the Wireless Code

Provide the following information related to how you continue to meet your obligations to promote the Code:

1. a description of the training you currently provide to customer service representatives to ensure that they are knowledgeable about the revised Code, able to effectively describe its provisions, and able to explain recourse options for customers.
2. the links to the consumer checklist set out in Appendix 2 to the Policy on your websites and screenshots of the website as required under para 426(b), and justify how these are “prominent”.
3. an example of the information you visually display from the consumer checklist in your stores and kiosks.
4. the notification you include in customers’ billing statements regarding the consumer checklist (see paragraph 426 of the Policy).

If there have been significant changes in how you train customer service representatives regarding the Code or in other aspects of how you promote the Code since your last compliance report, provide an overview of the changes.

Q8. Contracts with resellers

Confirm whether you currently provide telecommunications services to WSP resellers that are used in turn by those resellers to provide retail mobile wireless services.

If so, provide:

1. a list of the WSP resellers; and
2. confirmation that your contract (or other arrangement) with them continues to require that the purchaser of the service and their wholesale customers and subordinate wholesale customers adhere to the rules set out in the revised Code.

Q9. Manufacturer’s Suggested Retail Price (MSRP)

In The Wireless Code – Clarification of the term “manufacturer’s suggested retail price”, Telecom Decision CRTC 2022-294, 28 October 2022, the CRTC directed WSPs to collect and update MSRP data on a monthly basis, and to retain historical MSRP data to make it available to the Commission for Complaints for Telecom-television Services upon request. Explain how you:

• collect and update MSRP data on a monthly basis, and
• retain historical MSRP data to make it available to the Commission for Complaints for Telecom-television Services upon request.

Q10. International roaming

Paragraphs 218 to 224 of the Policy explain the Commission’s rationale for changing the rules related to the international roaming cap. Specifically, “if the cap was interpreted as not applying in the case of customers who have purchased roaming packages, there is a serious risk that the provision would not achieve its purpose.” To address this concern, the Commission introduced the term “roaming add-on”, to account for these roaming packages.

In a 7 October 2024 letter sent by the Secretary General, the Commission reminded WSPs that “the Wireless Code establishes a $100 cap on data roaming charges in a single monthly billing cycle. This cap includes all amounts paid by customers for fixed daily rate roaming options that include data, and plans that allow the consumer to use their phone abroad as they would at home.”

Please confirm how you currently apply the $100 international roaming cap in the case of customers using roaming packages that allow them to use their domestic plan’s voice, text, and data allotments while travelling, for a fixed price per day.

Further, please confirm that you require customers to explicitly agree to further charges beyond this cap.

Date modified:

2025-03-14