Search

Broadcasting and Telecom - Secretary General Letter addressed to the Distribution List

Gatineau, 30 July 2026

Reference: 1011-NOC2026-0134

BY EMAIL

Distribution List

Subject: Procedural requests from: Option consommateurs, Public Interest Advocacy Centre, Canadian Telecommunications Association, Forum for Research and Policy in Communications, and two individuals

On 12 June 2026, the Commission published Broadcasting and Telecom Notice of Consultation 2026-134: Harmonizing the consumer protection codes (the Harmonization Proceeding). The deadline for interventions is 11 August 2026. The public hearing is scheduled to begin on 30 November 2026.

Procedural Requests for Extension of Intervention Deadline

On 23 June 2026, Option consommateurs submitted a procedural request seeking to extend the intervention deadline to 30 September 2026 citing the scale of the work it needs to undertake to consider the questions in the proceeding. Option consommateurs also noted the potential overlap in deadlines with other ongoing proceedings:

On 7 July 2026, the Public Interest Advocacy Centre (PIAC) submitted a letter in support of extending the intervention deadline. PIAC added that the intervention deadline for another consumer-focused proceeding -- Telecom Notice of Consultation 2026-155: Show cause and call for comments – Compliance with the prohibition of fees that are a barrier to switching cellphone and Internet plans (Prohibition of Fees Show Cause Proceeding) -- falls on 30 July 2026.

PIAC acknowledged the importance of giving parties more time to meaningfully participate in the Harmonization Proceeding while also ensuring that there is no disruption to the hearing timeline. PIAC requested the Commission extend the intervention deadline to 16 September 2026, noting this is a reasonable and modest extension that will allow interested parties to have additional time to prepare their responses.

On 8 July 2026 the CTA submitted a letter indicating it does not oppose Option consommateurs’ request but proposed a deadline of 11 September 2026 to allow parties sufficient time to review the record and prepare for the hearing. The CTA added that the current deadline would require extensive coordination across multiple departments during a period when many subject matter experts are on leave.

On 16 July 2026 the Forum for Research and Policy in Communications (FRPC) supported Option consommateurs’ request to extend the intervention deadline, but proposed a deadline of 11 September 2026. FRPC noted that it too is participating in a number of Commission proceedings, namely:

On 23 July 2026 Marc Nanni submitted a procedural request seeking an extension of the intervention deadline without specifying an alternate date. They instead asked that “the Commission extend the timeframe for interventions to 2026-134, even if by only 5 days”. They also indicated that they intend to participate in other Commission proceedings, namely:

Marc Nanni also cited issues with the Commission’s website as a reason for the request, indicating that it had been intermittently offline to them for over 11 days, notably during the evening hours, making it difficult for them to participate in the Harmonization Proceeding.

On 26 July 2026, FRPC submitted a second procedural request seeking extensions of the intervention deadlines of a number of ongoing proceedings (Radio licence renewal proceeding [reply deadline was 21 July 2026], Unsolicited Telecoms Proceeding [intervention deadline was 27 July 2026], Prohibition of Fees Show Cause Proceeding [intervention deadline was 30 July 2026, the proceeding has since been suspended]; TELUS Part 1 Proceeding [intervention deadline was 28 July 2026], and CCTS Awareness Proceeding [intervention deadline has been extended to 7 October 2026]), including the Harmonization Proceeding, also citing issues with the Commission’s website. FRPC submitted that these issues have prevented them from accessing pertinent information and documents and requested an alternative intervention deadline of 25 August 2026.

Commission Determination on Requests for Extension of Intervention Deadline

The Commission notes that, since the receipt of the above requests:

The Commission acknowledges the workload associated with participating in its proceedings. At the same time, the Commission recognizes the importance of ensuring that its proceedings flow efficiently and deliver benefits to Canadians in a timely manner. The Harmonization Proceeding is the only proceeding cited by the parties that includes a public hearing; any postponement of intervention deadlines could lead to compressed timelines resulting in insufficient time for parties to examine the record and prepare for the public hearing.

With respect to Marc Nanni’s and FRPC’s claims regarding technical issues with the Commission’s website, the Commission notes that the website has experienced intermittent downtime recently; however, these issues have not lasted for significant periods of time. These issues, while disruptive, do not appear to have impeded fulsome participation in Commission proceedings, including the Harmonization Proceeding. The Commission notes that it has been receiving a regular stream of interventions from the public since its launch on 12 June 2026, including during the evening hours.

The Commission therefore denies all requests to extend the intervention deadline for the Harmonization Proceeding. The Commission considers that the recent changes to the deadlines of other proceedings noted above will strike the right balance between allowing parties more flexibility and time to participate in Commission proceedings, while minimizing disruption and delays.

Procedural Requests for Expanding the Scope of the Harmonization Proceeding

In its procedural request of 16 July 2026, FRPC requested that the Commission:

On 15 July 2026, Stephen Lawton submitted an intervention that included a procedural request to include specific questions in the Harmonization Proceeding on: whether advance billing serves consumer protection objectives; whether billing in arrears should be required; whether real-time balance visibility should be mandated, and how to balance consumer protection with operational considerations.

Commission Determination on Requests to Expand the Scope of the Harmonization Proceeding

The Commission clarifies that the subject matter of the Commission staff letter of 8 July 2026 in response to TELUS’ Part 1 Application (device unlocking) and the issue of advance billing are already within scope of the Harmonization Proceeding, which seeks comments on, among other things, whether any amendments to the codes (i.e. the harmonized code) are needed. Specifically, paragraph 16 of the Notice states that the Commission is seeking comments on the Consumer Protection Code Working Document, allowing parties to comment on all of the provisions contained therein. In Appendix 1 of the Notice (the Consumer Protection Code Working Document), the Commission instructs parties to identify any changes, additions, or removals to the existing wording, where necessary, providing alternative wording and supporting rationale.

With respect to publicly available reports cited by FRPC, the Commission notes that the manner in which the POR reports are linked in paragraph 11 of the Notice is in line with standard Commission procedure, and these reports are considered part of the record. Service providers’ annual Wireless Code and Internet Code compliance reports are similarly linked in the Notice, and can also be considered part of the record of this proceeding. To make it easier for all parties to locate these documents, the Commission is including links to each of the reports cited by FRPC in Appendix 1 of this letter.

With respect to FRPC’s request to provide evidence on the expectation expressed in the preamble to question 14 of Appendix 2 of the Notice—that harmonizing the Codes is expected to reduce administrative burden for all stakeholders—the Commission clarifies that this is an expectation and not a finding of fact. Further, the Notice sets out the reason for this expectation (that all of the consumer protections will be aligned under a single code), proposes a preliminary view regarding the Commission’s and CCTS’s roles, and asks parties to comment on this preliminary view. The Commission considers that submitting an intervention in this proceeding is the appropriate forum for expressing views regarding this expectation.

If you have any questions, please do not hesitate to contact Iva Jurisic, Senior Policy Analyst, Social and Consumer Policy, at Iva.Jurisic@crtc.gc.ca.

Sincerely,

Marc Morin
Secretary General and Executive Vice-President

c.c.: Scott Hutton, Vice-President, Consumer, Analytics and Strategy, CRTC, Scott.Hutton@crtc.gc.ca
Nanao Kachi, Director, Consumer, Analytics and Strategy, CRTC, Nanao.Kachi@crtc.gc.ca
Iva Jurisic, Senior Analyst, Consumer, Analytics and Strategy, CRTC, Iva.Jurisic@crtc.gc.ca

Appendix (1) – Links to POR and Service Providers’ Code Compliance Reports
Appendix (2) - Distribution List

Appendix 1 - Links to POR and Service Providers’ Code Compliance Reports

Public Opinion Research reports:

Annual Wireless Code and Internet Code Compliance Reports:

Appendix 2 - Distribution list:

aplourde@option-consommateurs.org
dbrady@piac.ca
adaly@canadatelecoms.ca
execdir@frpc.net
canadianconsumeradvocate134@gmail.com
mn_crtc@proton.me

Date modified: