Patrcia Ferguson MP
Convener, Scottish Affairs Committee
12 December 2025
Dear Convener,
Connectivity in Scotland: Digital connectivity
Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020, we are accountable to the Scottish Parliament. We work to ensure that consumer interests are at the heart of a fair, transparent and sustainable Scottish marketplace.
I am writing regarding the Committee’s current inquiry: Connectivity in Scotland: digital connectivity. Our response focusses on Questions 3 and 4 in the Call for Evidence.
Access to reliable and affordable communications is essential for many consumers and can help to ensure they can access a wide range of other goods and services. However, consumers in Scotland face a range of additional and differing challenges in relation to telecoms services compared to consumers in the rest of the UK. Ofcom’s Connected Nations report shows that, despite recent progress, Scotland still has many connectivity challenges. As of January 2025, 75% of premises in Scotland have access to a fixed broadband service compared to 81% of premises across the UK. Although take-up is in line with the UK average, Scotland still has the lowest level of full-fibre coverage of the four UK nations.
Around 10,000 premises in Scotland do not have access to a decent broadband connection, as defined in the Broadband Universal Service Obligation. Rural and island areas face overlapping disadvantages with lower connectivity speeds for both fixed and mobile technologies. In relation to mobile, only 37% of Scotland’s landmass has coverage from at least one network operator (at the High Confidence level) and Scotland continues to have the highest level of voice and text “not spots” across the UK nations, at 6%. Finding an affordable solution to these remaining connectivity issues will be a significant challenge in ensuring consumers across Scotland have access to adequate mobile and broadband connections.
Wherever possible, it is important that consumers have a level of choice between providers, to enable them to get the right services at a price that is acceptable to them. There may be a role for satellite technology in enabling more choice for consumers, particularly for consumers in remote and rural areas. We note from the Ofcom Connected Nations report that take-up of Starlink in Scotland continues to rise, with over 15,000 subscribers in 2025 compared to 11,000 in 2024. Approximately 2,000 of these subscribers are without access to decent broadband through other means. However, more competition is needed in this market for this to be a viable solution for connectivity for consumers across Scotland. We note that other Satellite broadband providers are likely to enter the market in 2026 and we welcome this, as competition is likely to ensure that providers compete on both price and on quality of service, which can bring benefits for consumers. We note that Satellite services are currently more expensive than equivalent fixed wireless or broadband services, with no social tariffs available, and consideration will need to be given to affordability of these services if Satellite is to be a realistic option to ensure connectivity across rural communities.
In relation to the transition to digital technologies, the phase-out of the Radio Teleswitch Service (RTS) is underway and, on current replacement trajectories, is expected to conclude by summer 2026, irrespective of wider digital transition in the energy and telecoms sectors. However, the future availability and design of dynamic and smart energy products and tariffs for some rural consumers in Scotland will increasingly depend on the quality and resilience of broadband connectivity. As the retail energy market is expected to offer more products and tariffs dependent on smart metering, dynamic pricing and time-of-use offerings, the reach and resilience of internet connectivity will be important for rural and island communities to access these products. For the 0.7% of GB households that the dedicated smart meter WAN cannot serve, the performance of 4G networks and fixed broadband connections, including for solutions such as Virtual WAN (VWAN), will be central to ensuring that rural households can access and benefit from these emerging products.
Further, Consumer Scotland has specific concerns about the impact of the migration to digital landlines (VoIP) on consumers in Scotland. For most customers, switching to VoIP should be straightforward and they will continue to receive what they recognise as a traditional phone service. However, VoIP landlines will not work in a power cut without additional backup systems being put in place. This in turn affects the operation of any devices linked to landlines such as telecare alarms.
In December 2023 we published our report, based on analysis of data produced by Ofcom’s Communications Consumer Panel. Our report found that consumers in remote and rural areas of Scotland face disproportionate impacts from the migration as a result of poorer than average mobile signal and more frequent and longer lasting power cuts. We highlighted that taken together, these factors affected the likely ability of consumers in Scotland to make calls in the event of a power cut.
We have recently seen power cuts affecting island communities in the Western Isles, Mull, Shetland and Tiree, resulting in lengthy power cuts. In many cases, mobile connectivity has also been simultaneously impacted by storms. Given that adverse weather is predicted to be even more frequent in future, we have serious concerns about the impact on consumers in Scotland, particularly those living in remote and rural areas where there is a greater level of compounded or cascading risk. This may be for example, where both power and landline services are affected, or where transport links and mobile phone infrastructure are also disrupted. We are aware that Ofcom has previously consulted on issues around cyber security and climate resilience. In our feedback to the regulator we highlighted our concerns around the adequacy of current back up measures in the event of power cuts, Norway and Finland have differential thresholds for battery backup times, with longer times required in sparsely populated areas. Consumer Scotland recommends that this approach should be considered in order to mitigate the disproportionate risks faced by consumers in remote rural parts of Scotland.
Improved resilience is required to ensure that rural communities are not cut off during adverse weather, as this would pose clear risks for consumers, and especially those in vulnerable circumstances. Current actions to support consumers during the migration to digital landlines have focussed on identifying and supporting telecare users. While we support these measures, further thought should be given to a wider range of consumers who may have support needs, including the needs of those who are pregnant or have young children, those with terminal illnesses or those with mental health conditions. We would urge providers to take continued action to ensure that consumers who may find themselves in vulnerable circumstances after the migration are also able to access support and backup where required. Without this action there is a danger that the migration process may fail those consumers whose circumstances change after they have moved to VoIP and who may not be aware of the support or backup that is available to them.
We would be happy to discuss these points in more detail with you and provide further information about our work on this topic.
Yours sincerely
Douglas White