UK Government consultation on telecommunications, radio spectrum and postal services

About us

Consumer Scotland is the statutory body for consumers in Scotland. Established by the Consumer Scotland Act 2020, we are accountable to the Scottish Parliament. The Act defines consumers as individuals and small businesses that purchase, use or receive in Scotland goods or services supplied by a business, profession, not for profit enterprise, or public body.

Our purpose is to improve outcomes for current and future consumers, and our strategic objectives are:

• to enhance understanding and awareness of consumer issues by strengthening the evidence base
• to serve the needs and aspirations of current and future consumers by inspiring and influencing the public, private and third sectors
• to enable the active participation of consumers in a fairer economy by improving access to information and support

Consumer Scotland uses data, research and analysis to inform our work on the key issues facing consumers in Scotland. In conjunction with that evidence base we seek a consumer perspective through the application of the consumer principles of access, choice, safety, information, fairness, representation, sustainability and redress.

Consumer principles

The Consumer Principles are a set of principles developed by consumer organisations in the UK and overseas.

Consumer Scotland uses the Consumer Principles as a framework through which to analyse the evidence on markets and related issues from a consumer perspective.

The Consumer Principles are:

• Access: Can people get the goods or services they need or want?
• Choice: Is there any?
• Safety: Are the goods or services dangerous to health or welfare
• Information: Is it available, accurate and useful?
• Fairness: Are some or all consumers unfairly discriminated against
• Representation: Do consumers have a say in how goods or services are provided?
• Redress: If things go wrong, is there a system for making things right
• Sustainability: Are consumers enabled to make sustainable choices?

We have identified access ,choice, fairness and representation as being particularly relevant to the consultation proposal that we are responding to.

Overview

DSIT is seeking views on the strategic priorities and desired outcomes for fixed and mobile digital infrastructure, the management of radio spectrum, telecoms consumers, telecoms security and resilience, and postal services.

Economic growth is the primary objective of the UK Government and the Statement sets out five strategic priorities to support growth, which Ofcom must have regard to when exercising its regulatory functions. Consumer Scotland welcomes the opportunity to respond to the consultation. Spending by consumers makes up a substantial component (over 60%) of 
economic output. As such, consumer confidence is integral to achieving growth.

With regards to the strategic priorities for telecommunications, management of radio spectrum and postal services, we observe two core routes through which it will be important for consumer confidence to be enabled, in order to support growth:

• Firstly, actions taken in these markets can deliver better value, lower-cost services for consumers which can contribute to wider economic benefits by boosting consumer spending power, giving consumers more money to spend on other goods and services.
• Secondly, the markets under consideration in this consultation provide different types of vital infrastructure which enable consumers to engage with a much wider set of goods and services across the economy. Consumers must therefore have confidence in the telecommunications, radio spectrum and postal services sectors, if they are to engage fully in the wider economy.

Alongside these points, we note that given the diverse needs of consumers in different regions in Scotland and the wider UK, measures should be in place to ensure the markets under consideration work well for consumers at a nations and regional level and reflect their needs. Ofcom, as regulator, should be empowered and required to ensure that nations-level and regional contexts are duly considered.

Strategic Priority 1: Driving growth through world-class fixed and wireless digital infrastructure

Supporting growth through access to gigabit-capable fixed telecoms connections

This priority aims to promote investment and competition between networks and encourage further build out of fixed networks to support this. Crucial to this is the monitoring of Openreach’s activities where competition does not yet exist, or is limited in scope, along with the imposition of remedies, where necessary, to prevent risks to competition.

Consumer Scotland supports this priority. This work can help to deliver greater levels of competition, which can drive improvements in service, promote innovation, deliver enhanced choice for consumers and provide greater incentives for communications providers to price competitively to attract consumers.

The UK government has proposed that:

• to support Universal Access, Ofcom must monitor pricing differences in gigabit-capable broadband between geographic areas and localities
• in areas of the UK with only one network operator Ofcom should, alongside 
  government, consider steps to ensure consumers do not have to pay excessive prices due to a lack of local competition
• Ofcom must also work with government to review the Broadband Universal Service Obligation and make any appropriate changes.

Consumer Scotland supports proposals for work to promote a better understanding of geographical differences in how competition is working for consumers across the UK. Consumers in Scotland face a range of additional and differing challenges in accessing telecoms services when compared to consumers in the rest of the UK. While there has been recent improvement, consumers in Scotland face geographic disadvantages, with 
communities across remote and rural Scotland experiencing particularly poor connectivity. Ofcom’s Connected Nations report shows that, despite recent progress, Scotland remains by many metrics the least connected of the four nations. 73% of premises in the UK have access to full fibre from at least one operator. This compares to 65% for Scotland and 44% for rural 
Scotland. There is a clear risk that as the digital divide narrows in urban areas it may continue in more rural areas. Looked at on a sub-national basis, there is a disproportionate risk that consumers in rural areas in Scotland will not benefit from the advantages of competition and may find it difficult to switch supplier. Action by Ofcom to ensure consumers are not exposed to excessive prices will be particularly important for consumers in these areas.

Consumer Scotland supports measures to address inequalities in access to crucial services, which can in turn support economic growth. Removing barriers to accessing products in different markets is a critical part of ensuring equitable access to resources, and the economic gains that this brings.

Audit Scotland has found that currently nine per cent of households in Scotland have no internet access at all. In this regard it should be noted that provision of infrastructure alone will not deliver Universal Access. It will also require measures to boost take up, ensure affordability and support the development of digital skills. Ensuring these supporting measures are in place will also help to realise crucial human rights, including the right to 
education and a fair trial. Audit Scotland found that one in six Scottish adults lacked the digital skills needed for everyday life, blocking them from accessing public services.

In relation to delivering improvements in Universal Access, we recommend that the measures proposed in the consultation should be expanded to also include work by Ofcom, in tandem with efforts by providers, and third sector partners, to improve consumer understanding of what services will meet their needs, to ensure affordability and to develop digital skills. This might, for example, include:

• providing information on the benefits of moving from legacy technology in a clear and accessible way either via providers or by national information campaigns
• requiring providers to ensure that affordable products are more available to 
  consumers, including though facilitating greater availability, promotion and uptake of social tariffs

In relation to the Broadband USO, Consumer Scotland supports a prompt review of this. Around 16,000 premises in Scotland do not have a decent broadband connection, and rural and island areas face overlapping disadvantages with lower connectivity speeds for both fixed and mobile technologies.

We recommend that a review of the adequacy of the current minimum connectivity threshold of 10 Mbps should be a core part of the USO review. Over 70% of premises across the UK are already accessing speeds of 30Mbps and higher and it is an important principle of consumer fairness that those reliant on the USO for a broadband connection should not 
experience a significantly poorer service than other consumers. It is important that USO provision maintains pace with improving commercial speeds, to avoid creating an ever-growing divide in consumer experience. 

We recommend that detailed work should also be undertaken by Ofcom and the UK Government to deliver new payment options that can make USO broadband more affordable and accessible for those consumers who are unable to pay for excess connection charges in full in advance. This is important as those consumers who are still lacking a decent connection are likely to be those who are the most difficult to connect and who may face the 
largest costs. Consideration must given to the role of satellite technology in fulfilling USO requirements. We welcome the current Ofcom consultation on use of satellite connectivity to support smartphone coverage in remote areas.

In relation to supporting take-up of Gigiabit, it is proposed that Ofcom must report every 6 months on takeup, coverage and the use of One Touch Switch. The Statement directs Ofcom to take all efforts to support effective and straightforward switching between providers in order to enable competition so that more consumers can benefit from gigabit broadband.
This includes supporting greater use of consistent terminology between providers.

Consumer Scotland notes the significant benefits to consumers in being able to access gigabit-capable networks compared to the legacy copper network, including higher speed, higher capacity, and lower fault rates. In addition, gigabit-capable networks are a more future-proofed option which can allow upgrades to support higher speed services as demand increases. In line with the consumer principles of access and choice, we support the aim of promoting competition and investment in high quality gigabit-capable networks in order to bring faster, better broadband to consumers across the UK.

Consumer Scotland supports measures to increase consumer confidence, specifically through improved switching processes. Consumers need to have confidence to try new products, switch services and providers, and shop around. However, they will be more likely to do this if they are confident that markets work for them – that they are protected against unsafe products and unfair trading, and that they will be able to achieve redress when things 
go wrong.

We have previously noted the difficulties in ensuring that competition operates fairly across the UK, with Scotland having fewer providers and experiencing lower levels of connectivity. This highlights the need for strong consumer representation and engagement with policy makers and regulators. This links to our recommendation below that the UK Government 
should consider the need for statutory consumer advocacy. These geographical realities also underline the need to focus on ensuring adherence from dominant network operators to the Quality of Service standards. It also highlights the need for measures allowing competitors 
such as alternative network providers to participate in a fair and equal way.

Ofcom’s monitoring should address not only the possibility of price differentials due to a lack of competition, but should also assess the reliability of services offered, and the responsiveness of service providers when issues are raised. It is important that those consumers who are reliant on the Broadband USO or the services provided by dominant operators do not receive a poorer service or experience. In the event that Ofcom’s monitoring detects issues in relation to competition, reliability or the responsiveness of 
service providers, we would expect Ofcom to take prompt action to mitigate or avoid harm to consumers, even if this harm is only occurring in certain geographical areas.

For consumers to be active in the market, and play their role in driving faster overall economic growth, a number of elements must be in place. Consumers must be in a financial position which enables them to purchase essential goods and services with confidence. Consumers rely upon digital means to provide them with access to many other goods and services. Consumers must therefore have confidence in the digital markets and 
communications sectors if they are to engage fully in the wider economy. Given this, policy interventions to improve consumer outcomes in the communications sector should be considered not only in terms of their own importance, but also in terms of the foundational role the sector plays in enabling consumers to help drive wider economic growth.

Finally, under this strategic priority, to support the modernisation of telecoms networks Ofcom is directed to collaborate with the telecoms industry, government, and other partners (like the telecare sector) to ensure that there is no significant adverse impact on Critical National Infrastructure throughout modernisation programmes, and that vulnerable consumers are adequately protected.

Consumer Scotland supports the proposal for this work. We have undertaken a range of work regarding the move from PSTN to digital (VOIP) calling. A variety of lessons have been learned from this process and it is important that these are captured and applied to any future technological changes which are implemented. These lessons include:

• the need to ensure consumer facing information is simple, timely and uses consistent language across providers 
• the need to identify underlying factors which might affect the risk of consumer vulnerability (such as health conditions, a risk of facing longer lasting power cuts or poor mobile connectivity)
• the need for swift and effective monitoring and enforcement to protect consumers from harm. There is a need for clear ownership, allocation of actions and resources and transparent monitoring to ensure that consumers can trust regulators and networks to deliver the services they need

The involvement of consumer organisations at an early stage in the design of any modernisation processes can help to ensure that these lessons are properly embedded. Engagement with consumer organisations throughout any implementation process should also continue to ensure that issues affecting consumers can be promptly identified and addressed.

Supporting growth and productivity through investment in high-quality 5G networks

The draft priorities propose that Ofcom must proactively identify where effective competition may not exist in the market, assessing the impact of market dynamics and technological developments on investment in network infrastructure. It is proposed that Ofcom should continue to work closely with the Competition and Markets Authority, under concurrent competition powers, on issues that cut across sectoral and competition concerns. We note the desire for regular reporting on the cost of regulation to industry, the 
impact of this on investment and the need to consider how to support long-term investment and growth in telecoms networks.

Ofcom is also tasked with continuing to improve the quality of its coverage reporting on mobile network availability and quality, including reporting on coverage across road and rail infrastructure. Ofcom is to report at both country and constituency level and should review thresholds of what constitutes “good” coverage to ensure these definitions continue to 
reflect consumer and business expectations as user requirements and behaviours evolve.

Consumer Scotland supports the plans for this work. The Connected Nations Spring update shows that there are still notable differences in ‘not spots’ in Scotland compared to the UK, with Scotland having 10% of 4G total not spots vs 4% for the UK and 7% voice and text total not spots compared to 3% for the UK as a whole. Consumer Scotland supports measures to 
encourage investment targeted at delivering network enhancements and allowing more effective competition. We also strongly support measures allowing consumers to assess the likely coverage that each provider can deliver in local areas under “real world” conditions. Ofcom should engage closely with consumer organisations as it undertakes its work on coverage reporting, to ensure that this delivers positive consumer outcomes. 

Policy and regulatory interventions can provide certainty and confidence for investors to put money into economic sectors, developing new services and products. This can achieve ‘win win’ outcomes for businesses and consumers. Those businesses which meet certain standards to deliver positive consumer outcomes generate a significant competitive advantage. For consumers, regulation can help to give them confidence in a sector, which can support positive economic growth by boosting consumer spending power and giving consumers a solid, reliable foundation upon which to make purchasing decisions. Consumer confidence can also be boosted by having effective monitoring and enforcement and Consumer Scotland supports the use of concurrent powers by Ofcom and the CMA to protect consumers against unfair practices, or misleading or inaccurate communications by 
providers.

Strategic Priority 2: Driving growth through maximising access to spectrum

Work under this priority will cover a range of measures, including implementing new spectrum management techniques, adopting innovative technologies that enhance spectrum efficiency, and enhancing spectrum sharing, where appropriate.

Consumer Scotland supports these measures. We recommend priority is given to measures to ensure appropriate access for major users whose roles underpin access to other services such as the transport sector and emergency services. Spectrum may also play a valuable role in resilience and backup solutions, especially in rural areas and we recommend that this 
work also be treated as a priority area. We support carrying out work to consider the future Spectrum needs associated with delivery of digital terrestrial TV services.

Strategic priority 3: Supporting growth through a transparent, competitive, and fair retail market

Consumer Scotland is of the view that it is necessary to take a balanced and proportionate approach to considering the cost of regulation. When considering this issue, regulators and governments should also consider the costs of consumer detriment that is caused by ineffective or inadequate regulation. Consumer detriment occurs when problems cause people stress, cost them money, or take up their time. The 2024 Consumer Detriment 
Survey surveyed more than 6,300 individuals across the UK (and more than 850 in Scotland) to understand consumer detriment experiences in the 12 months leading up to May 2024. Overall, the net cost of consumer detriment was estimated to be £4.0 billion in Scotland and £71.2 billion in the UK – equivalent to approximately 4.3% of total UK household consumption expenditure for the same time period. The total net monetised detriment 
across the UK for the internet provision sector was estimated at £3bn, with mobile telephone services accounting for £1.6bn and TV and digital subscriptions for £1.5bn. This represents a considerable economic cost being borne by consumers.

The study found the proportion of consumers experiencing detriment in relevant sectors to be as follows:

• 24% of UK consumers who purchased internet services 
• 17% of consumers who purchased TV and digital subscriptions 
• 15% of consumers who purchased mobile services

Overall, consumers in vulnerable circumstances were found to be more likely to experience detriment, with younger consumers and those with low financial resilience also more likely to experience detriment. Those consumers with a long-term health condition affecting their day-to-day life were not only more likely to experience detriment, but also experienced 
greater financial costs, emotional distress, and adverse mental and physical health impacts as a result.

Effective regulation can play a role in decreasing financial and other costs to consumers and enabling them to spend money safely and confidently. For example, interventions to prevent consumers from experiencing financial harm, or to mitigate this harm if it does occur, can help to give consumers more money in their pocket, which they are then able to spend on other goods and services.

In order to sustain and improve overall satisfaction measures, work under this priority will require Ofcom to work with operators to address specific concerns about customer care, ensuring that complaint handling processes are fit for purpose and that redress pathways are clear and offer a consistent experience for consumers. Ofcom is directed to seek opportunities to improve the consumer experience in the telecoms sector, particularly for 
vulnerable consumers, including those with disabilities and those who are financially vulnerable. The aim is to encourage operators to adopt a more consistent approach and, where possible, share data to ensure that vulnerable consumers are accurately identified, and getting a consistent level of support.

Ofcom must continue to monitor the affordability of telecoms services, undertaking analysis and establishing a regular, consistent reporting cycle, able to highlight trends and changes over time.

Ofcom is also to explore other ways to improve consumer confidence in new and emerging broadband and mobile retail providers and to work with operators to identify and address the vulnerabilities in telecoms networks that are exploited by criminals. Ofcom will assess the potential merits of establishing a Smart Data telecoms scheme.

Underpinning this work, is the need to ensure that regulations are informed by the groups and individuals they are likely to impact. Ofcom must engage with those affected by regulatory changes, and with the Communications Consumer Panel on issues likely to affect consumers of telecoms services, giving due weight to the Panel’s views and opinions.

Consumer Scotland strongly supports the consideration and implementation of measures to protect the position of consumers across the issues of customer care, affordability and consumer confidence. We agree that the consumer experience should be central to determining the approach to regulation in these areas. We strongly support the development of measures to protect consumers in vulnerable circumstances. We acknowledge that Ofcom has previously developed, in 20022, the Treating Vulnerable 
Customers Fairly guidance. However, since this was developed there have been developments in other regulatory environments such the Financial Conduct Authority’s Vulnerability Review and the development by Ofgem of its new Consumer Vulnerability Strategy. We recommend that Ofcom review its guidance to ensure it draws upon subsequent learning and best practice across sectors.

Examples of interventions in the above policy areas that should be specifically considered by the government and Ofcom include:

• Measures to increase awareness and promote take up of social tariffs 
• Improvements to redress systems to tackle consumer detriment, such as the swift and straightforward provision of refunds if a service or product is not provided to the standard required or specified
• Improved support to prevent consumers from falling into debt or to help tackle problematic debt when this occurs
• Improved signposting to sources of support or redress such as advice agencies or Ombudsmen services
• Improvements to complaint handling processes such as measures to improve the speed and transparency of these. In particular we would wish to see Ofcom consider, and comment, on any sub-national differences in complaints to ensure that any Scotland specific issues are highlighted and addressed, in both communications and postal services
• Targeted engagement or enforcement measures to improve areas of persistent poor performance either across the industry or by individual providers
• Incentivising effective use of customer data and customer feedback by providers, to encourage more focus on delivering better outcomes for consumers
• Continuing measures to reduce the prevalence of scams where consumers are targeted via electronic communication services, whether email or messaging services.

We note that Ofcom is encouraged to consider how they can best contribute to addressing digital exclusion and promoting safe participation. Consumer Scotland considers that digital inclusion is a vital part of encouraging participation across society and across multiple markets. To participate safely, services must be accessible and affordable and people must 
have the skills and confidence necessary to engage. Consumer Scotland would welcome a stronger focus in this area, and would encourage Ofcom to work with the UK and devolved Governments, the Digital Regulation Cooperation Forum, UKRN, consumer bodies and the third sector to explore opportunities for collaboration.

If Ofcom is to accurately assess the effect of regulatory measures, or regulatory gaps on consumers, it is crucial that it engages effectively with consumer bodies and can take account of a diverse range of communications services, user experiences and voices. Consumer bodies in turn require staff time and resources, for example, in commissioning 
research and conducting engagement activities, to provide an informed input to consultations and engagement with the Ofcom. The telecoms sector is an outlier amongst regulated utilities in not having a levy funded consumer advocacy mechanism. Such a mechanism exists in the gas, electricity, postal services, water and heat networks sectors. The UK Government has previously consulted on the potential for a formal consumer advocacy mechanism in the telecoms sector and we would encourage DSIT to revisit this issue to explore how the establishment of more formal consumer advocacy and advice mechanisms can inform the work of government, the regulator and industry, ensuring that the consumer experience is understood and central to the policy and regulatory decision process.

Strategic priority 4: Maximising opportunities for growth through secure and resilient telecoms infrastructure

This priority sets out that the government, Ofcom and the telecoms industry must work together to ensure the UK’s networks and infrastructure are appropriately and proportionately protected against threats and hazards and can respond effectively to disruptive incidents affecting the UK’s networks or services.

Consumer Scotland notes the importance of Ofcom’s work to ensure that our electronic communication services are resilient to disruption. The government’s resilience priorities in this area include:

• Work to reduce the likelihood of power cuts leading to a loss of services and reduce the impact of any loss of services to consumers.
• Ensuring publicly available data on incidents and outages is more detailed, interactive, and transparent
• Ensuring spectrum management delivers effective regulated access for Satellite emergency calls
• Continued work to assess the risks of climate change and set resilience standards and guidance to communications providers 
• Secure, resilient, and innovative telecoms supply chains

Consumer Scotland supports this work but notes that there remain significant challenges in developing and maintaining our infrastructure given the likely increase in the volume and impact of severe weather events. As set out in our work on VOIP, Scotland experiences a higher prevalence of these events, especially in more rural areas. A key risk to digital landlines and mobile networks is the availability of mains electrical power as interruptions to this could result in consumers being unable to use communications services. Developing appropriate resilience measures will require collaboration between energy and telecoms providers, regulators, governments and local authorities.

We continue to have concerns that consumers in rural areas of Scotland are particularly vulnerable to interruptions to service due a combination of poorer mobile signal, the remote locations of some infrastructure and the lack of backup solutions in place. It may take considerably longer to restore power in some rural areas than in urban areas, meaning that different and longer lasting backup solutions may be required.

We recommend that enhanced investment should be prioritised by Ofcom, and providers, in areas where there are more frequent and longer lasting power cuts, areas where there are a limited number of MNOs with adequate signal or where there are few overlapping sites that can employed in the case of equipment failure. Ofcom should continue to work together 
with communications providers and wider forums such as the Electronic Communications Resilience and Response Group to improve monitoring and reporting regarding the resilience of communications networks and to deliver improved consumer outcomes in response to resilience issues.

Strategic priority 5: Supporting growth through resilient and sustainable postal services

Ensuring the provision of the universal postal service

This priority obliges Ofcom to consider the needs of users of postal services, particularly vulnerable customers and businesses that rely on the service, while providing appropriate incentives for Royal Mail, as the universal service provider, to continue to make the necessary investment to modernise the business.

Supporting growth

The strategic priority to support growth through postal markets is critical to consumers and small businesses across Scotland and the UK. The postal service connects consumers to goods and services in the wider economy and consumer confidence in the postal market is therefore a key factor in enabling small businesses and individuals to be active economic 
participants, contributing to growth.

Quality of service

The consultation notes that it is a key priority for government to ensure that customers can expect a reliable postal service, and that Royal Mail should be incentivised to meet the quality-of-service targets that Ofcom consider meet the reasonable needs of users. The consultation highlights that this will require continued proactive engagement, monitoring Royal Mail’s delivery of its quality-of-service improvement plan, and taking appropriate and 
timely action where failures are identified.

Consumers have had a poor experience in the postal sector in recent years, with Royal Mail failing to meet its Quality of Service delivery targets for first and second class post over a number of years. The company was fined of £5.6 million for missed delivery targets in 2023 and was fined £10.5 million in 2024. It is again under investigation for its failure to meet targets in 2024-2025.

In July 2025 Ofcom introduced a number of changes to the universal service which reduce the level of service provided to consumers. The new USO model has introduced alternative delivery days for second class post, and it is not yet clear how effectively this new model will work for consumers. In this context, it is essential that there are appropriate and proportionate incentives to ensure that quality of service targets are achieved.

There is limited evidence to date that the current enforcement regime is helping to achieve the required improvements in Royal Mail’s quality of service performance to ensure that consumers have a reliable postal service. In this context, we recommend that the UK Government and Ofcom, with input from consumer organisations, undertake a broader assessment to ensure that Ofcom has the necessary tools to achieve compliance by Royal 
Mail with its regulatory requirements for quality of service, enabling consumers to receive the service they require.

The new USO arrangements include a new UK-level ‘tail of the mail’ reliability target to monitor the proportion of first class mail delivered within three working days and second class mail within five working days. Consumer Scotland has recommended that monitoring of this target should include monitoring at nation or postcode area level. This would help ensure that rural and remote consumers do not experience a poorer service than consumers elsewhere and are able to rely on postal services to engage effectively in the wider economy.

As the new USO arrangements are implemented, it will be important that these are closely monitored to ensure they are delivering a reliable service for consumers, to enable them to contribute to the government’s stated strategic priority. We recommend that Ofcom should undertake consumer research, designed with the input of consumer bodies, to test:

How well consumers have been informed of the changes to the postal system

• If consumers have understood these changes 
• What impact the changes have had for consumers’ experience of the mail system 
• What actions, if any consumers have taken to mitigate the impact of these changes

Ofcom should publish the findings from this research and commit to follow up mitigation and monitoring work as required on the key issues identified.

As well as being reliable, it is important for consumers that the postal service is affordable. The price of first class stamps has risen rapidly in recent years. We are aware that Ofcom is planning work on affordability of services later this year and it is important that this work proceeds at pace and delivers robust protections for consumers, to ensure they can continue to make effective use of postal services.

In relation to the postal sector specifically, Consumer Scotland has a particular interest in the monitoring of compliance with complaint handling standards. The Consumer, Estate Agent and Redress Act s.45(2) requires Consumer Scotland and other statutory advocates to consider publishing statistical information relating to levels of compliance with complaint 
handling standards. Our current position is that due to existing publications, including by Ofcom, there is no requirement for Consumer Scotland to make a separate publication, however we are committed to engaging with regulators to improve the quality of the data already gathered and published. While recognising that Ofcom already publishes some Scottish specific data in interactive tables available online, Consumer Scotland wrote to 
Ofcom in September 2024 to request that Ofcom considers explicitly highlighting nation-level differences in complaints within written reporting based on the tables, such as the Annual Post Monitoring Report or reporting on the Residential Postal Tracker.

We have also made a number of recommendations to Ofcom to strengthen the implementation of its complaints handling guidance for parcel operators, to help improve consumer outcomes in this sector.

Importance of bulk and access mail

Ofcom’s regulatory framework requires Royal Mail to provide access to its network to other postal operators or users but delivery standards are agreed under contracts with those access operators and not monitored by Ofcom. Much important mail that consumers rely on falls outside of the scope of the universal service obligation and Ofcom’s regulatory quality of service targets. Ofcom must give due regard to the importance of bulk and access mail on 
different postal user groups and access operators, and assess whether further regulatory interventions are needed to ensure high levels of reliability for all users of postal services. Similarly to our feedback above, close monitoring will be required by Ofcom to assess the impact of recent USO changes on bulk and access mail, to ensure that these changes are not 
delivering effectively for consumers, enabling them to contribute to the strategic priority of growth.

Security and resilience of postal services infrastructure

Ensuring the security and resilience of the UK’s universal postal service network is a strategic priority for the government. The consultation notes that while contingency planning is an operational matter for Royal Mail the government will seek to increase collaborative working with Ofcom, Royal Mail, and the national technical authorities to further shared interests in a resilient and sustainable postal service. It will be important for consumer 
organisations to be involved in these processes as appropriate, to ensure consumer interests are well understood and addressed.