Thank you for your letter dated 28 March 2024 outlining the risks associated with the migration from the Public Switched Telephone Network (PSTN) to a fully digital based service.

Firstly, as you will already be aware, responsibility for the UK’s telecommunications network is reserved to the UK Government, with the Department for Science, Innovation and Technology being the lead government department.

Universal Service Obligations

It is worth noting that the PSTN migration does not affect the Universal Service Obligations set in the Electronic Communications (Universal Service) Order 2003 which require the designated providers to offer telephony services throughout the UK, and providers will remain bound by their existing statutory responsibilities.

Ofcom, the independent telecoms regulator, has issued guidance on how telecoms companies can fulfil their regulatory obligation to ensure that their VoIP customers have access to the emergency services in such circumstances. This guidance states that providers should have at least one solution available that enables access to emergency organisations for a minimum of one hour in the event of a power outage in the premises. The solution should be suitable for customers’ needs and should be offered free of charge to those who are at risk as they are dependent on their landline.

Customers who are not eligible for a free resilience solution should be able to request one but their provider may charge for it. Customers who are moving to VoIP services and are reliant on their landline should discuss their situation and requirements for a back-up solution with their provider before they are moved on to VoIP services.

Mobile Services

Emergency calls can be made on any mobile network, not just the network the customer uses. If a mobile phone has no signal, but displays the phrase “emergency calls only”, the mobile phone will automatically connect when 999 is dialled using the nearest available network.

Nearly all homes in the UK are covered by at least one mobile network for making voice calls. However, where a customer is located in a total not-spot (where there is no outdoor coverage on any 4G network) for mobile coverage, their provider should ensure they have a method of contacting the emergency services in the event of a power outage.

UK-wide initiatives will also bring coverage improvements in Scotland. The Shared Rural Network (SRN), led by the UK Government’s Department for Science, Innovation and Technology (DSIT) and the UK’s four main network operators (O2, EE, Vodafone and Three) will make very significant investments in 4G coverage: up to £1Bn to increase 4G access to 95% of the UK’s landmass (which equates to around 91% of Scotland’s geography). This is a substantial increase on the current coverage levels of around 44%.

The project’s first step will be to focus on ‘partial not-spots’, those areas where 4G is only available on one or two providers. Followed by 'total not-spots', areas where there is no coverage from any network provider. Further information is available at

As this is a UK Government programme, we cannot confirm which areas will be included. However, we are actively exploring ways that the Scottish Government and SRN can work collaboratively to ensure Scotland achieves maximum benefits.

In addition to this, BT recently announced it would address mobile “not-spots” through further investment. In the past 12 months, they’ve improved mobile coverage in more than 500 areas across the UK. BT will look to extend coverage in a further 900 locations by 2024.

Although the telecommunications sector is reserved to the UK Government, we understand the importance of increasing telecoms resilience, particularly in rural areas, which is why we continue to deliver the Scottish 4G Infill Programme (S4GI), where we are investing £28.75 million in future-proofed infrastructure to improve rural and island 4G mobile coverage.

The programme is delivering 4G services to 55 not-spot areas which will improve mobile telecoms resilience by increasing the overall network coverage in Scotland. 32 masts are currently live, and the remainder will be complete this spring.  Scottish Government remains in close dialogue with the UK Government and the mobile industry on UK Government-led initiatives such as the Shared Rural Network and the Emergency Services Mobile Communications Programme which will also increase access to 4G services in rural, remote and island areas across Scotland. Both programmes are making use of our S4GI infrastructure to achieve mutual aims and we continue to seek opportunities for further alignment. 

PSTN Charter

On the 18 December 2023 a number of Communications Providers signed a Public Switched Telephone Network charter, where signatories (full list at link below) commit to the following:

  1. We will not undertake any non-voluntary migrations to digital landlines, until we have full confidence that we are taking all possible steps to protect vulnerable people through the migration process.

  2. No telecare users will be migrated to digital landline services without us, the customer, or the telecare company confirming that they have a compatible and functioning telecare solution in place.

  3. Where battery back-up solutions are provided, we will work to provide solutions that go beyond the Ofcom minimum of 1 hour of continued, uninterrupted access to emergency services in the event of a power outage.
  4. We will collectively work with Ofcom and Government to create a shared definition of ‘vulnerable’ customer groups that require greater support, specific to the digital landline migration.

  5. We will conduct additional checks on customers who have already been non-voluntarily migrated to ensure they do not have telecare devices we were unaware of, and if they do, ensure suitable support is provided.

Public Switched Telephone Network charter - GOV.UK (


The Digital Office for Scottish Local Government have been working closely with Local Authorities and telecare service providers across Scotland to identify challenges to ensure a smooth and safe transition to a digital service for citizens in receipt of telecare in their home environments. Additionally, my officials have been active in facilitating information briefing sessions between Openreach and Scottish Local Authorities to ensure they have the most up to date information.

Electronic Communications – Resilience and Response Group

My officials continue to work closely on the resilience of the telecoms network in Scotland with UK Government, Industry, Ofcom and other Devolved Administrations through the Electronic Communications – Resilience and Response Group (EC-RRG) whose aim is to develop and maintain cooperation between the Communications Sector and Government on issues regarding resilience and emergency planning. The EC-RRG work together both in planning for and responding to disruptive events, as well as promoting the availability and resilience of electronic communications across the UK. 

In addition, my officials remain a close line of communication with individual telecoms operators prior to and during disruptive events to help coordinate response and reporting arrangements to both the responder community and Scottish Ministers. Scottish Government Officials also contribute to National debriefing exercises.

Resilience Partnerships and Response

Resilience partnerships are formed by the statutory responder agencies who come together to prepare for civil emergencies. These partnerships have carried out work to familiarise the constituent members with the challenging consequences of power failure, so that they can build resilience into their own business continuity arrangements and plan for how they will serve the public in these circumstances. As mentioned previously, the PSTN switch off is a commercial and operational decision for operating companies. Resilience partnerships have received briefings and information to allow them to prepare for how their services will run when this change is completed.

The Civil Contingencies Act 2004 places duties upon statutory responders to plan, co-operate, share information, assess risk, develop business continuity and warn and inform the public. Scottish Government does not direct responders in how to fulfil their legislative duties under the act.

My officials are working closely with industry, Ofcom and UK Governmernt and are ensuring that information relating to the switch off is being shared widely across SG policy areas and the responder community, including local authorities and emergency services.

Priority Services Register

Should someone be considered vulnerable to severe risks from a power cut due to a disability or other personal issues, they should seek advice from their Network Operator by calling 105, as they may be eligible to be added to their Priority Services Register. Those on the register are eligible for support in the event of power outages, including advance notice of outages and priority assistance in a planned power outage.

Ready Scotland

For further information in preparing for the potential loss of power, Scottish Government’s Ready Scotland website (Advice for emergencies in Scotland ( has a wealth of advice, guidance, and resources to help people prepare for emergencies and disruption. There is existing advice on Ready Scotland for how to prepare for a loss of power supply, and what people can do if it happens. Emergencies and disruptions can happen at any time and we can all be impacted in some way.

I hope that this response has been helpful. Yours sincerely

Richard Lochhead

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