The electronic communications market is, and has been since its liberalisation, a commercial competitive market. Thus, the provision of electronic communications services, is a matter for private sector service providers, regulated by the independent regulator, the Commission for Communications Regulation (ComReg). ComReg recognises the desire by providers of electronic communications services to move their customers to e-billing and understands the potential benefits accruing from increased take-up of e-billing (including cost and environmental benefits). ComReg also recognises the desire by some consumers of electronic communications services to move to e-billing. However, any move to e-billing should take full account of, and safeguard the legitimate preferences and interests of consumers and comply fully with licence and other applicable legal requirements. In this regard, ComReg published a consultation on consumer bills and billing mediums on 28 October 2011 to seek the views of interested stakeholders on a number of proposed measures in relation to consumer bills. I am advised by ComReg that it notified Vodafone on 25 October 2011 that it had not complied with certain conditions of its licences and certain related statutory obligations with respect to electronic billing. Under Regulation 16 of the authorisation regulations and Regulation 31 of the Universal Services Regulations, Vodafone has two weeks within which to state its views on ComReg's finding, or to remedy its non-compliance. The regulations also provide that if, at the end of the two-week period, ComReg is of the opinion that Vodafone has not complied with its obligations, it may apply to the High Court for such order as may be appropriate by way of compliance with those obligations.
