Telecom - Staff Letter addressed to Philippe Gauvin (Bell Canada)

Gatineau, 9 May 2025

Reference: 1011-NOC2016-0293

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19, 160 Elgin Street
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Subject: Wireless Code Compliance – Apparent non-compliance of Bell’s device locking practices

Dear Philippe Gauvin,

Through a letter sent in confidence to Douglas Heath, Director General, Telecommunications Policy, Telecommunications, Bell Canada and its flanker brand Virgin Plus (Bell) informed the CRTC that they intend to start selling locked wireless devices to address an increase in crime at its points of sale. This was change was made public through notifications sent to Bell’s customers as reported by Mobile Syrup^Footnote1 on 24 April 2025.

While I appreciate the need to take action, your current approach is in apparent breach of the Wireless Code and Bell has demonstrated in the past that there are other ways to ensure the security of Canadians, including employees and customers, that remain in compliance with the Wireless Code.

To ensure that customers have the benefits of unlocked devices, the Wireless Code requires that service providers ensure that devices are unlocked at or before the time of sale, without requiring any specific action on the part of the customer.

This requirement encourages the development of a more dynamic marketplace. Unlocked devices offer more consumer choice and convenience, contribute to a decreased risk of bill shock by providing options to consumers while travelling abroad, and reduce a significant barrier to switching wireless service providers by improving device portability.

I share Bell’s concerns for the safety of Canadians, including employees and customers. However, Bell’s solution of locking devices for a period of 60 days following purchase or requiring customers to request that their device be unlocked would appear to put Bell in non-compliance with the Wireless Code.

Bell acknowledged using a similar approach to curb robberies in the proceeding leading to Telecom Decision CRTC 2019-169.^Footnote2 However, at the time, Bell automatically unlocked devices as part of the activation process. This raises questions as to the justification for Bell now locking devices for 60 days post-purchase to address similar concerns.

Please explain how you intend to ensure that Bell remains in compliance with the unlocking rules set out in the Wireless Code by responding no later than 16 May 2025.

Yours sincerely,

Scott Hutton
Vice-President, Consumer, Analytics and Strategy (CAS)

Date modified:

2025-05-09