Please see below a communication we have received from Vodafone with regards to the handling of Premium SMS traffic from 13th January 2018.
Vodafone has now had time to consider the implementation of the Payment Service Directive (PSD2) which going forward needs to be known as Payment Services Regulation 2017 which is coming into effect on 13.1.2018 and as the legislation has passed across with no mitigation for the Electronic Communications Networks (ECNs) in the scope of the number ranges captured (scope remains 09x 118x 0871/2, VSC, PSMS and CTB. Bulk SMS and Bulk MMS are out of scope) therefore it is vital that Vodafone and partners take action to remain in compliance with this legislation.
As you will be aware the transposition/implementation document from HM Treasury is that the exclusion from FCA PSR regulation cascades down along the value chain. This simplifies many things but the introduction of new transaction limits means that the phone-paid services element of Vodafone needs to adapt to the £40 per transaction limit and the cumulative £240 a month spend limit. The FCA has confirmed separately that the Network Access Charge is NOT part of these limits and so the only element of interest in voice calls is the Service Charge (inc VAT) portion of the cost to the consumer.
Therefore, this is official notice that there are important requirements that will need to be acknowledged and actioned by you as our partners in order to comply with the spend caps imposed by the PSR 2017.
1. All captured voice calls must be terminated before the customer reaches the £40 transaction limit based on service charges only. Please note that if there is existing OfCom/PSA regulation regarding number ranges (adult etc) at a lower level, these lower limits remain the requirement.
2. All PSMS services will need to be diverted into Charge to Bill transactions (in the same way that Charity Donations are today) using the ER platform. This is so that the existing transaction, daily and monthly spend limits can be used to regulate the customers PSMS expenditure. Vodafone will send out a detailed guide to these requirements.
What does this mean for Fonix customers
1. We will be transitioning all PSMS billing over to charge to bill on the Vodafone network
2. All Shortcodes will be submitted to Vodafone by Fonix to implement the change
3. The change will take place on an agreed date and time with codes being switched over in stages to minimise the impact to clients
4. The change will be staggered from 7th December and your account manager will contact you to discuss the process
5. Fonix will create logic to support the switch to charge to bill so there is no requirement for customers to integrate into a separate API
6. Vodafone has confirmed there is no current plans to change the commercial terms
Please do not hesitate to contact us if you have any questions
Kind regards
Fonix Operations Team
Posted Nov 08, 2017 - 16:17 GMT
This scheduled maintenance affected: Premium SMS Gateway.