Connected consumers: Making telecommunications markets work for consumers in Scotland

The telecommunications market plays a vital role in enabling consumers in Scotland to access an extensive range of goods, services and markets, including healthcare, social security, banking, education, retail, social networks and entertainment. Access to these markets is critical to consumers’ wellbeing, to enabling their active participation in the economy, and to supporting citizens’ access to vital public services.

Over the past two decades there has been extensive rollout of a wide range of fixed and mobile technologies across Scotland. This has transformed how consumers access and interact with services and many consumers benefit from access to high speed, reliable and affordable telecommunications services.

However, consumers in Scotland can face a range of challenges with accessing telecoms services. While there has been recent improvement, some consumers in Scotland can face geographic disadvantages compared to those in other parts of the UK, with many rural and island communities in Scotland experiencing particularly significant challenges across both broadband and mobile markets. Other consumers face barriers to accessing digital markets and to maximising the benefits while mitigating the risks, due to limitations in cost, confidence and digital skills.

Ongoing action is needed to tackle connectivity gaps, improve access, and boost digital inclusion, reducing the digital divide and allowing consumers in Scotland to participate fully in an increasingly digital society and economy.

While real terms prices have fallen in certain key markets, purchase decisions are becoming increasingly complex, with more options for consumers to choose from. Levels of competition in the market are not uniform across the UK; many areas in Scotland, especially rural and island communities, have lower levels of coverage from more than one provider in both broadband and mobile markets. This can reduce the ability of consumers to move providers in search of a better deal.

Consumers need access to accurate information about provider coverage and about their own usage to support good purchase decisions. In order for consumers to benefit from the advantages of a competitive market, they will often need to take actions such as switching, renegotiating or reconfiguring bundled contracts. Not all consumers are able to confidently negotiate, and further support is needed to help consumers get the best deals available for them.

Where competition is not effective, there is a risk of market stagnation and poor consumer outcomes. Consumers need clear pathways to resolve issues where things have gone wrong. Levels of consumer detriment in the telecommunications market remain relatively high, indicating a need for continued consumer protection and effective enforcement.

Given ongoing cost of living pressures experienced by consumers, affordability remains an issue. A lack of affordable access to data or devices, a lack of skills or digital confidence, or a lack of motivation to use the internet can all contribute to digital exclusion, leading to a lack of access to wider services and opportunities.

In this report we present a package of recommendations aimed at ensuring equitable access to telecommunications services for consumers in Scotland. Equitable access can allow everyone to take up opportunities to work, connect and contribute to our society and communities.

Connectivity

While the rollout of broadband services continues to gather pace, gigabit and superfast coverage continues to lag significantly in rural and island areas of Scotland and presents a clear risk of digital inequality. The gap in gigabit coverage for rural Scotland is particularly pronounced. There also remain around 10,000 premises in Scotland who still cannot receive even a “decent” broadband service using either fixed line or fixed wireless access technology. This can create barriers to consumers accessing services, including challenges associated with the operability of energy smart meters.

Access to “decent” broadband speeds is delivered via the Broadband Universal Service Obligation (USO), which is due to be reviewed. We recommend that this review commences in 2026 and that it raises the speeds specified in the USO to at least the equivalent of Superfast Broadband levels, to support effective consumer confidence and participation across the economy and society. Any review should draw on the possibilities offered by developments such as the rollout of satellite technology, standalone 5G and 6G mobile services to enable “hard to reach” properties to access reliable telecommunications services. It is also important that USO connections remain affordable to ensure services are accessible to as many consumers as possible and to prevent detriment.

We recommend continued detailed monitoring and reporting on any revised USO, as well as improvements to consumer information so that consumers can better understand when various technologies are expected to be available to them. The Scottish Government should build also upon the outcomes of the Broadband USO, updated information on Planned Network Deployments by Providers and the outcomes of the Mobile Markets Review to refresh Scotland’s Full Fibre Charter. This must clearly identify the actions it, and partners, will take to improve connectivity.

Both 4G and 5G mobile coverage in Scotland also lag behind other UK nations, with Scotland having the highest number of landmass areas lacking coverage in mobile services. Both the UK and Scottish Governments have funded work to improve mobile connectivity, but coverage and performance remain at their lowest in rural areas. This impacts on the experience of consumers in Scotland. Further action by governments, providers and regulators is needed to assess coverage and performance levels of 4G and 5G provision in Scotland and identify priority areas for further investment. Following the publication of the most recent work on planned network deployments, and the conclusion of the Mobile Markets Review, Ofcom should establish nations-level benchmarks for mobile performance to accompany its proposed 90% UK benchmark to ensure delivery of significant performance improvement in Scotland and the other UK nations. The Scottish and UK Governments should work together to identify and agree priority areas for further investment both by providers and governments to meet these benchmarks. Decisions must draw on the possibilities offered by new technologies such as 5G standalone services, future 6G rollout or direct to device satellite calling to identify the most cost-effective solutions for “hard to reach” areas.

Supporting consumers during technology upgrades

The retirement of legacy technology such as the 2G and 3G mobile phone networks and older generation landlines poses challenges for both providers and consumers. Consumers need better information to help them understand what is changing and what action they need to take.

Consumers in rural areas of Scotland could be at risk of harm due to the switchover to digital landline calling and the retirement of 2G and 3G services adds another layer of complexity when looking at overall resilience of services. Throughout these network upgrades, technology must support consumers’ needs for uninterrupted access to calling and messaging services, connected health care services and critical public services.

Issues in the retail market 

Advances in technology and increased competition between providers are allowing consumers to access better quality services for lower prices. Effective switching at the end of any fixed term contract can help consumers get best value, but consumers need accessible information about what deals are available and best meet their needs. Consumers can find it difficult to access this information and negotiate deals. Where contracts allow mid-term increases, it can be difficult for consumers to understand the effect of these provisions. Without measures to promote more transparency, consumers in vulnerable circumstances risk missing out on the best deals, meaning that they pay more for their services.

Given the importance of telecommunications services in consumers’ daily lives, the services received must be of appropriate quality. There must be clear ways for consumers to raise issues where things go wrong or where they are dissatisfied with the services they receive. While the UK Government has set out clear expectations of providers as part of a new Telecoms Consumer Charter, the Consumer Detriment Survey indicates that issues with internet provision, mobile telephone services and TV and other digital subscriptions all cause significant detriment to consumers.

The telecommunications sector can also improve the way it responds to the needs of consumers in vulnerable circumstances. We recommend that Ofcom urgently refresh its guidance on supporting consumers in vulnerable circumstances, building on the Charters developed by the UK Government and telecoms industry. Clearer guidance across issues such as pricing, contractual terms and debt recovery practices is needed and new guidance should clearly set out Ofcom’s approach to how consumers can be encouraged to share relevant information about their needs with providers and the actions providers should take.

Digital Exclusion and Affordability 

Digital exclusion continues to affect consumer access to public and private services. Public Service Reform in Scotland offers opportunities to transform service delivery. However, action will be needed to ensure that reforms are rigorously assessed for their impact and user-tested to ensure inclusive design. This should include building in provision of assistance to access digital public services from the start to avoid some consumers being excluded from services. Affordability of telecommunications services remains a key issue. While the number of social tariffs available has increased, a lack of consumer awareness continues to dampen take-up. Although the price of broadband and mobile services has fallen in real terms, and broadband and mobile social tariffs offer a safety net for those struggling with their bills, for many on very low incomes the price of connectivity still remains too high.

Consumer Scotland recommends that the UK Government and Ofcom continue to work with providers to raise awareness and take-up of social tariffs. Ongoing monitoring will be needed and Ofcom should also consider whether the makeup of social tariffs and the allowances included reflect what consumers need to undertake work, engage socially and access public services. We also recommend the zero rating of essential public services websites so that consumers can access these sites without needing data.

The Scottish Government should also work to boost affordable access to devices and access to affordable (and where necessary free) data.

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 internationally. To inform our approach and that of others Consumer Scotland has adopted a set of consumer principles, drawing on the internationally recognised principles adopted by the UN General Assembly, to underpin our policy analysis and development and help assess the consumer interest.

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?

Objectives of this review

Since our inception in 2022, Consumer Scotland has undertaken work on a range of telecommunications issues on behalf of consumers in Scotland. Our work has included advocacy on access to telecoms services, pricing, competition, safety, resilience and redress. Following these specific pieces of work, we wanted to assess the overall consumer experience of purchasing and using telecommunications services in Scotland. This review, which has comprised an in-depth examination of the existing evidence base, delivers our assessment of the current situation for consumers in Scotland: It:

• Identifies the key issues affecting telecommunications consumers in Scotland
• Assesses the effectiveness of current policy and regulatory responses to these issues
• Recommends priority areas for further action which can improve outcomes for telecoms consumers in Scotland

The work is intended to provide evidence and insight that will inform the actions of regulators, governments, industry and other stakeholders. It will also inform Consumer Scotland’s future research, policy and advocacy priorities in the telecommunications market.

Telecoms as a vital consumer service

UK adults spent an average of 4 hours and 20 minutes a day online in May 2024,[1] an increase of almost an hour from the September 2019 level of 3 hours and 29 minutes.[2] As the internet plays an increasingly central role for people carrying out everyday tasks such as purchasing goods, accessing services and communicating, consumers have an ever-growing need for high quality internet and mobile services. Faster, more reliable telecommunication networks, with greater geographic reach, can support innovation, transformation of public service delivery, and access to better business and leisure services. These networks allow consumers to remain in touch with friends and family and play an important role in maintaining access to critical national services such as healthcare or emergency services.

In the round, the availability of fast, reliable and affordable telecommunications for consumers, businesses and service providers underpins key purchasing, investment and delivery decisions and is a key driver of economic growth and efficient public service delivery.

Ensuring equitable access to these networks for consumers across the nations and regions of the UK is essential, to enable all consumers to access opportunities to work, connect and contribute to our society and communities.

Telecommunications services in Scotland are provided by a variety of technologies, including fixed-line, mobile telephone, wireless and satellite connections. A short description of the current deployment of these technologies in Scotland is provided below. This provides the context for the following sections, which examine how well these technologies are currently serving consumers.

Landlines and Fixed Line Broadband

Fixed-line (“landline”) connections to residential and business premises were historically the main broadband service used by consumers. These are provided by Openreach’s network, made up of copper cable, ducts and poles. With the arrival of high-speed broadband internet access, fixed-line connections are now also provided by fibre-optic and coaxial cables which carry voice and data transmissions. Openreach was originally owned by BT but is now a separate company under the BT group. Openreach maintains and builds the phone and broadband infrastructure and it is required by the regulator Ofcom to make this infrastructure available to competitors. It has been estimated that more than 650 service providers use the Openreach network, including major internet service providers (ISPs) such as BT, TalkTalk, Plusnet and Sky.[3]

The telecommunications regulator, Ofcom, has also encouraged competitors to build their own networks, rather than relying on network access from Openreach. Virgin Media O2 provides cable and fibre broadband services and cable landlines. Through a combination of its own network and access to open-access wholesale fibre networks, the company’s combined fixed-line broadband covers more than 18 million homes across the UK.[4]

More recently, alternative network (“altnet”) services have emerged, which offer both retail services as ISPs and wholesale services. Altnet services are now available across around one third of the UK, through approximately 100 operators. Provision is dominated by a small number of larger operators, such as CityFibre, Hyperoptic, and Community Fibre, although there are also a large number of smaller altnets.[5]

Mobile, Wireless and Satellite Services

In addition to fixed line services, telecommunications services are also provided using mobile telephone technology. Mobile network operators (MNOs) own and manage the physical infrastructure for the mobile telephone network; these are EE, O2, Vodafone and Three.

In addition, there are a range of mobile virtual network operators (MVNOs) who resell mobile telephone services using MNO infrastructure. Many of these are provided by widely recognised companies, including Tesco Mobile, Lebara, TalkTalk or Sky mobile.

MNO and MVNOs provide their services using a variety of digital wireless communications technologies. These include voice and messaging services delivered via 2nd generation (2G) to 5th Generation (5G) services. This technology also provides Fixed Wireless Access (FWA), a wireless internet-only connection delivered via 4G or 5G technology that provides internet services from a mobile telephone mast to an antenna or router installed at the customer’s premises.

An expansion of FWA networks offering high-speed broadband services (of at least 100 Mbps download speeds) is underway with nearly 7,000 FWA masts being planned or upgraded across the UK between January 2026 and January 2029.[6]

Telecommunications services can also be provided by either Geostationary Orbit (GSO) or Low Earth Orbit (LEO) satellite services. GSO services are provided by companies such as Brdy, Eutelsat-Konnect, Northsat and Freedomsat, and LEO services in Scotland are provided by Starlink and OpenWeb.[7] Ofcom has consulted on expanding spectrum availability for GSO satellite gateway earth stations across most of the UK landmass, predominantly in rural areas with low population density..[8]

Ofcom has recently authorised direct LEO satellite to mobile phone connections,[9] with Vodafone and O2 being licensed to undertake “direct-to-device” satellite telephone calls.[10] Satellite direct-to-device services have the potential to provide basic connectivity to mobile handsets in areas outdoors where there is currently no coverage by terrestrial mobile networks - and therefore could potentially improve connectivity in rural “not spots”. However, Ofcom cautions that these services are still at an early stage of development. In the short to medium term, the focus is expected to be on SMS and low speed data services (under 500kbps) which can be used for services such as messaging apps. Voice services are intended to be introduced as the technology and satellite constellations mature. As a result, it is unlikely that direct-to-device satellite services will be used to support broader connectivity needs in the near future. [11]

This chapter outlines the current rollout and availability of broadband and mobile coverage across Scotland. It provides a comparison between Scotland and other UK nations and between urban and rural areas, identifying areas where coverage is weaker. It also addresses consumer issues as a result of the retirement of legacy technologies such as the move to digital voice calling and the retirement of 2G and 3G mobile services.

The Urban-Rural Gap

Of the 32.5 million premises with access to fixed broadband services in the UK, 2.9 million of these are in Scotland.[12] In Scotland, as in the other devolved nations, there are a significant number of rural telecommunication services consumers. Ofcom estimates that there are 590,801 rural telecommunications consumers in Scotland, representing 20% of all consumers in Scotland.

Communications issues have particular relevance for rural consumers. Rural areas often have more dispersed populations and residents may need to travel longer distances to access goods and services. Public transport infrastructure to facilitate this can be more limited, meaning that rural consumers have a greater reliance on online services. Reliable communications systems are needed for rural consumers to secure their safety and peace of mind, carry out social engagements and undertake work and business activities. Ofcom highlights that connectivity also supports the sustainability of rural communities, allowing business to grow, innovate and compete, while rural communities depend upon successful businesses to support jobs, services and long-term economic resilience. [13]

Consumer protection

This chapter assesses the impact of advances in technology and the effect of competition between providers on consumers. It addresses switching, as well as discussing issues around transparency of pricing and the adequacy of information provided to consumers. It also considers common causes of complaints and how well these are addressed.

Ofcom can set conditions “protecting the interests of the end-users of public electronic communications services” and these are generally implemented and enforced through the General Conditions of Entitlement for providers. These set out consumer protections in relation to contract requirements, information and transparency, billing, complaints, measures to meet the needs of vulnerable consumers, switching, sales and marketing. In addition, providers must comply with the provisions of the Digital Markets, Competition and Consumers Act 2024, which sets out a number of unfair or misleading practices which should be avoided, as well as creating new protections in relation to drip-pricing, subscription traps and fake reviews.

The UK Government has entered into a Telecoms Consumer Charter with a number of providers, as part of a commitment to ensuring that “all consumers feel confident, informed and empowered when engaging with the telecoms market”. The Charter aims to embed transparency, support consumers in financial difficulty and strengthen trust. Not all providers have signed up to this Charter and it should be noted that any Charter measures building further on Ofcom’s rules are voluntary in nature.

While a detailed analysis of how the retail market operates is beyond the scope of this report, we use the following sections to highlight issues where the retail market can pose challenges for consumers and where intervention may be needed to help consumers get better outcomes.

Consumer Engagement – Switching and Getting the Best Deal

Consumers have a variety of choices when paying for services. When it comes to mobile services, they can choose to pay monthly via a fixed term contract, to pay “as you go”, to bundle handset and SIM costs or to pay for SIM only services, with various bundles of calls and data.

Fixed line services can be for broadband or landline only and can also be bundled with related streaming and television services.

Fixed-term contracts for mobile telephone and fixed-line broadband connections are the most common way to pay for telecommunication services, with UK-wide research for Citizens Advice finding that 70% of UK adults pay for telecommunications services this way.[84]

Citizens Advice found that, of those consumers who enter a fixed-term contract, almost half (48%) tried to negotiate a new contract with the same provider at the end of their contract term. Less than a third (28%) choose to switch provider when their contract ends, while a quarter (26%) are out of term on their contract. Less than a fifth (18%) take out a new contract with their existing provider without negotiating.[85]

With advances in technology, and increased competition in the broadband market from altnets, Ofcom found that average broadband prices fell in real terms last year by an average of 6%. Consumers may now be able to switch to faster, more reliable full-fibre broadband product for the same - or a lower - price than they previously paid for a copper or part-fibre service. Ofcom found that 28% of broadband customers are out of contract and, on average, in contract customers spend between £7 and £9 a month less than out-of-contract customers.[86]

Mobile airtime prices are also continuing to fall; SIM only consumers on unlimited data contracts saw costs drop by 8% in real terms last year.[87] In general, consumers are getting more for their money with Ofcom research showing that between 2020 and 2025, the price of an average-use basket of mobile services fell by 20% in real terms, despite average data use more than doubling.[88]

In order to get a deal that meets their needs, consumers need to know that they are out of contract and can get a better deal from switching or from reconfiguring the services that they take (for example from bundling services or moving to a SIM only contract once a handset is paid off).

Consumers also need to be able to negotiate the switching process. Consumers can find the process of switching difficult, and provider behaviours can contribute to this. Ofcom recently fined Virgin Media £28M for systemic failures in dealing with telephone calls from consumers who wished to cancel their contracts between 1 January 2022 to 11 September 2024. Ofcom found that Virgin Media had engaged in deliberate call-dropping tactics, excessive and unnecessary call transfers and putting customers repeatedly on hold for no reason, leading to consumers being prevented or delayed in accessing better deals.[89]

In recent years, Ofcom have put in place measures to protect consumers and to make it easier for them to access deals. For example, mobile handsets can no longer be sold “locked” to a particular network. Providers must notify consumers when they are out of contract and let them know the best deals available via end of contract notifications (ECN). Where a consumer remains with a provider but is out of contract they must also remind them of this and let them know about the best deals through an annual best tariff notification (ABTN).[90] Ofcom has also developed coverage checkers to allow consumers to check provider coverage in their area when deciding whether to switch. As noted elsewhere in this report, Ofcom continues to work to present coverage and performance information in a more consumer friendly way and to improve the accuracy of this data.

Changes have also been made to the switching regime to make it easier for consumers to switch using the “One Touch Switch” service for broadband and “AutoSwitch” for mobile. These changes mean that consumers no longer need to contact their old providers to let them know they wish to cancel, a requirement which had led to the issues outlined above in relation to Virgin Media. An increased choice of providers, a wider range of deals and measures to improve the switching process have all contributed to rises in switching behaviours.

Following these reforms, Ofcom research found that around a quarter of households changed provider for at least one communications service last year. However, it also found that switching rates are lower for older consumers and those in lower socio-economic groups, who may feel less confident in comparing deals.[91]

Mobile Pricing Practices

Ofcom announced a ban on inflation-linked mid-contract price rises in new mobile phone contracts entered into from January 2025. This followed a rise in complaints to Ofcom as consumers experienced large and unexpected price rises due to strong underlying inflationary pressures in the economy.[92] Ofcom research found that more than half of pay monthly mobile customers and broadband customers did not know what inflation indexes such as the Consumer Price Index (CPI) and Retail Price Index (RPI) measure, and often found it difficult to estimate what the impact of these measures might be on their own contract prices.[93]

Under the new rules any price-rise written into a telecommunication customer’s contract must be expressed in pounds and pence (£/p) and be set out prominently and transparently, at the point of sale.[94] Despite these attempts to provide more contractual certainty, and enable consumers to plan and manage their budgets, some consumers have still experienced significant mid-contract price increases under the new regime.

For example, O2 imposed a mid-contract price increase which was specified in pounds and pence (£2.50 per month on their mobile contracts, a 40% increase in the contract price) which was criticised by both Ofcom and other stakeholders.[95] The UK Government asked Ofcom to revisit its rules in light of O2’s higher than expected price increase.[96] The Telecoms Consumer Charter sets out a clear commitment to the new pricing model and limits mid contract price increases in fixed term contracts to circumstances where unforeseeable and externally driven events materially affect the cost of providing services. It also set out arrangements for out of contract “legacy” consumers to move to this new pricing model.[97]

Reflecting how the telecommunications market works, Ofcom has committed to undertaking a full analysis of the impact of the new rules in 2026-27,[98] as part of ongoing work to help consumers have access to affordable mobile services. Consumer Scotland supports work to conduct prompt monitoring and evaluation of the new measures given ongoing cost of living pressures on consumers. Following this analysis, Ofcom should publish its approach to how it will ensure that pricing policies can best balance the need for a fair commercial return for providers with consumer needs for affordable, transparent and fairly delivered services. It is critical that consumers understand how much their services will cost for the entire duration of their contract so that they can appropriately budget for current and future costs.

Transparency

Given that fixed-term contracts are the primary purchase method, it is important that contract terms are fair and transparent and that consumers understand important contract elements, such as duration and price.

Citizens Advice have undertaken UK-wide research looking at factors which can prevent consumers from getting the best deals when re-contracting at the end of their fixed-term contracts. They noted that many consumers found negotiations difficult or stressful, especially where consumers were experiencing mental health problems, had cognitive or neurological disabilities or were in financial hardship. They found a lack of transparency in the process due to “asymmetric information” in three key areas:[99]

• Consumers don’t know about all the tariffs their provider can offer
• Consumers don’t know how much other consumers are paying for the same services
• A consumer’s current provider knows more about their usage and spend than competitor providers and so can offer more tailored deals

As a result, Citizens Advice has proposed changes to address these challenges and to reduce the need for consumers to contact their provider to access the best deals, including requiring providers to provide more information to consumers about their usage and to make any “best deal” offers clearer. Citizens Advice also wish to see “open data” schemes developed and more information published on current prices. [100]

The UK Government has recently directed Ofcom to assess the potential merits, and costs and benefits, of establishing a Smart Data scheme in telecoms, including examining whether this can be achieved on a voluntary basis.[101]

Consumer Scotland supports proportionate measures to ensure that consumers understand what they need from telecommunications services. We support the recommendation from Citizens Advice that providers should inform consumers of their annual or monthly usage. This can support consumers to identify which tariff works best for their needs and such information is routinely provided in other sectors such as energy, via monthly bills. In addition to usage, it would be helpful for consumers to understand what different speeds and packages offer in a more user-friendly way. What usage would a 10GB data package allow for example or how long would it take to download a podcast or streamed movie using the advertised speed? Information that allows consumers to move beyond abstract numbers and understand what they can do with each package would support improved decision-making.

Consumers should be able to access available deals using a variety of communication channels. Having to rely on calling an existing provider to negotiate and to access deals is something that will not work for every consumer, especially consumers in vulnerable circumstances. Providers should be required to give consumers clearer information about their usage and the best available deal across a wider range of communication channels, including any app or website accounts, to ensure the contractual process better meets consumer needs.

Even with this additional information provided, consumers who are less confident in negotiating, or who have cognitive impairments or other disabilities that make it difficult for them to access services such as switching sites, may find it hard to get the best deal. They are likely to be reliant on friends and family negotiating for them and providers may refuse to speak to supporters who are not named account holders. This may lead to the higher proportion of consumers in vulnerable circumstances being left on legacy deals or out of contract pricing. Ofcom should consider whether there is a case for developing assisted digital services that would facilitate engagement in switching and contract negotiation for consumers who would otherwise struggle to do this themselves.

Quality of Service and Detriment

Telecommunications services play an ever-increasing role in helping consumers access goods and services. Given this role in helping consumers access other goods and services, telecommunications services must be of appropriate quality. There must be ways for consumers to raise issues when things go wrong or where they are dissatisfied with services.

Ofcom can enforce consumer law on behalf of consumers but does not have the power to resolve individual consumer complaints about telecoms or postal services. Where appropriate, Ofcom can provide advice to consumers and refer them to Alternative Dispute Resolution schemes that Ofcom has approved.

Ofcom undertakes some thematic analysis of complaints data in its quarterly telecommunications sector complaints report.[102] Ofcom categorises complaints by consumers across 3 areas:

• Faults, service and provisioning (including technical issues)
• Complaints handling
• Billing, pricing and charges

“Technical issues” can include issues with broadband download/upload speeds or frequent drops or disconnections in service. Other technical issues raised include poor network coverage and reception. Complaints handling encompasses long wait-times to speak with customer service agents, and the use of chat bots.

For fixed-line services, the most significant driver of complaints is technical faults, service and provisioning, with the industry average rate at six complaints per 100,000 customers for fixed-line broadband and three complaints per 100,000 customers for fixed-line telephone or landline services.[103]

For pay monthly mobile complaints rates ran at two complaints per 100,000 customers and for pay TV they ran at two complaints per 100,000. There was a reduction in pay monthly mobile complaint rates in the most recent figures, which follows on from a previous rise in complaints about contractual issues as a result of mid-contract price rises by some mobile providers, including O2.[104]

Citizens Advice’s UK-wide research found that technical issues were the most common reasons for consumers contacting their consumer advice service. Issues raised in relation to fixed term contracts for fixed line or mobile services included damaged or faulty equipment, service outages and poor connection (21%), followed by billing problems, such as unexplained charges, mid-contract price rises or paying more for the same service than new customers, known as the loyalty penalty (20%).[105]

Issues around the quality of telecommunications services received by consumers are also reflected in the UK Government’s Consumer Detriment Survey.[106] Consumer detriment is defined as where consumers experience problems with a good or service that causes stress to them, costs them money or takes up time.[107] The survey found that purchase level detriment, or the detriment experienced by consumers who have purchased services within a given market sector, is 24% for internet provision. This purchase level detriment ranks as the fourth highest level of detriment experienced by consumers after public transport and train services (29%), second-hand vehicles (28%), and adult care (26%).[108]

The report also assesses population level detriment, which is the proportion of all consumers who experience detriment in a given sector, whether or not they purchase within it. Population level detriment for internet provision was high, at 24%.[109] Mobile telephone services (15%), TV and other digital subscriptions (17%) also rank highly on measures of population level detriment, while fixed telephone services were at 10%.[110]

Net monetised detriment, or the level of financial loss for consumers across the UK, was estimated at £3bn for internet provision, £1.6bn for mobile telephone services and £1.5bn for TV and digital subscriptions.[111]

Many of the issues complained about by consumers are long-standing issues, giving rise to concerns that systemic weaknesses in provider complaints systems have not been adequately addressed. The UK Government has stated that it is important that overall satisfaction is sustained and improved where possible. They have requested that Ofcom work with operators to address specific concerns about customer care, with a view to ensuring that complaint handling processes are fit for purpose and that the routes available for consumers to escalate their concerns, such as Alternative Dispute Resolution services, are clear and offer a consistent experience for customers.[112]

This work appears to be additional to that set out in Ofcom’s Plan of Work for 2026/27. Consumer Scotland strongly supports this work, would welcome further details on what is intended and will engage further during any review.

Looked at as a whole, there are some encouraging developments across the sector for consumers. Broadly, consumers can:

• access more data and more comprehensive packages for less money than was previously the case
• have more choice about the types of packages they consume
• can switch more easily and with less friction than previously, and
• can access increasingly reliable data about the performance of services in their area

However, they are still experiencing challenges, including

• understanding provider pricing practices
• navigating the increasing complexity of the market, understanding what packages meet their needs and what terminology means
• accessing deals using a method that works for them
• raising and resolving issues when they do occur

There remains a risk that consumers in vulnerable circumstances will be unable to negotiate better deals, or resolve contractual issues, meaning that they pay more for their services. While recent reforms are helpful, we recommend that Ofcom:

• undertakes further research on consumer understanding of pricing practices and other key contractual provisions
• monitors switching, price and other recent reforms to ensure that they are effective and publicly reports on this
• considers how to give consumers more information about their usage so that they have more control when negotiating contracts
• considers whether assisted digital services could help consumers who are not currently engaged in switching or who have trouble resolving issues with providers

As consumers increasingly use digital means to access services, digital exclusion has become an increasing risk for some consumers. This chapter considers the issues that digital exclusion can cause and addresses current issues around affordability of services.

Digital exclusion and access to essential services

The increasing pace of technological change has resulted in essential services which were previously provided in a “real-life” setting, such as healthcare, banking, education, and social security often moving online. Leisure services such as shopping, social networks and entertainment are also increasingly accessed and consumed in an online or digital-only setting.

Digital exclusion can take many forms, including a lack of access to a stable and affordable internet connection, the right sort of device, or the skills needed to complete tasks confidently and safely online.[113] It can result in consumers being excluded from public services, social opportunities and access to goods and services.

Audit Scotland recently carried out an assessment of how well the public sector in Scotland is tackling digital exclusion and what more it can do to tackle this.[114].

It found that digital exclusion affects consumers who:

• Are unable to afford an appropriate device or internet connection
• Do not have the skills and confidence to use digital technology
• Have a fear or mistrust of using online services or lack the motivation to do it
• Have difficulty in accessing digital services and devices or an internet connection
• Are unable to keep up with the pace of change of digital technology[115]

The research showed that 15%, or approximately one in six adults in Scotland lack the digital “foundational skills” to do things such as turn on a digital device, connect to the internet, use an internet browser, or update a password.[116] Nine per cent of households did not have access to the internet. The report also noted strong associations between digital exclusion, poverty and people with certain protected characteristics,[117] including age. Age was a key factor, with people who are retired and aged over 65 years being less likely to use the internet.[118]

Similarly, Ofcom’s research on digital disadvantage has also found that digital exclusion intersects with a wide range of personal characteristics relevant to other forms of social exclusion, including age, socio-economic status, disability, geography, education, literacy, language and housing circumstances. Ofcom’s research demonstrated that certain groups of consumers are more likely to experience challenges in accessing and using the internet including:

• Disabled people
• People in insecure housing
• People from minority ethnic groups
• People with Limited English Proficiency and
• Less frequent internet users[119]

Key challenges for consumers when accessing the internet included:

• Logging into online accounts: remembering passwords, PINs, usernames, security information and other login details, and having to manage multiple login credentials
• Complex interfaces: websites with less intuitive or familiar designs that were difficult to navigate
• Online forms: complicated and long online forms that require lots of information (e.g. health registration forms, mortgage application forms, or benefits forms) hosted on online platforms that are deemed difficult to use. This included issues of forms with multiple pages, forms where information could not be saved, or forms where information could only be inserted in a particular format
• Appointment booking services: where forms have restrictions on how much or what type of information can be provided within it, with no option to speak to an adviser over the phone to clarify required information[120]

Previous negative consumer experiences with online services, such as online scams, fraud and data breaches also contributed significantly to digital exclusion.[121] Online banking was a particular concern, along with websites that required consumers to provide personal or financial information, such as e-commerce websites.[122] Anxiety about identity theft, risks and banking safety contributed to a general mistrust of online services and a tendency to avoid using unfamiliar websites.[123]

Audit Scotland found that more needs to be done in order to tackle digital exclusion.[124] The Scottish Government’s Connecting Scotland programme, launched in May 2020, was shown to have a positive impact on tackling digital exclusion and improving digital skills.[125] From May 2020 to December 2021, the programme provided support to over 61,000 households to access the internet, including provision of digital devices, internet connections and skills support. However, funding for the programme has been reduced and evaluation of the programme has identified sustainability concerns over the level of investment required to provide free data packages and one-to-one support by digital champions.[126]

Audit Scotland’s work also highlighted that digital inclusion in public services can help people to realise their human rights, secure better outcomes for vulnerable people and allow people to use digital technology and tools safely and securely to access services in a straightforward way. They identified that implementing this approach would require:

Collaboration – working across sectors, with private and third sector, including place-based approaches

• Clear and coordinated plans and strategies
• Using person centred and tailored approaches
• Making sure staff have the appropriate digital skills to support and build capacity amongst users
• Supporting people at point of need, and
• As part of service design and reform – involving people who use services and taking account of everyone’s needs[127]

Audit Scotland additionally note that this will require robust equality impact assessment to identify consumers’ needs and risks of harm. It also requires consumers to have affordable access to devices and data, the skills to access services and/or the provision of digitally assisted services where they are needed to support access. There must be clear information and routes to support users and these should be based in local, trusted places.[128]

The Public Sector Reform programme potentially offers some opportunity to address these issues, but will only be effective if all consumers can access the services they need. The Scottish Government has committed to publishing a Digital Strategy setting out how they will accelerate the digitisation of Government. It will also look at the potential for apps to access personalised government services and the potential to extend government use of secure digital identity information. It promises to apply user centred and more efficient approaches to deliver better outcomes.[129] The Scottish Government’s Sustainable Digital Public Services Plan[130] is also welcome and sets out a vision for public sector leadership, common approaches and the use of date which will be taken across the Scottish Government and local authorities. We encourage regular updates to the plan and the development of the actions it sets out up to and beyond 2028.

Mitigating the risk of digital exclusion will require action from regulators, providers and governments. We recommend that the Scottish Government addresses these issues in its work on digital inclusion and on public service reform. It should:

• Ensure that reform of public services delivery is rigorously impact assessed and user tested to ensure inclusive design
• Ensure that provision of assistance to access digital public services is built in to service design from the start to avoid exclusion from services
• Work with Ofcom and the UK Government to help consumers improve digital skills which can boost consumer confidence in using online services

As noted earlier in this report, Ofcom should also act to ensure that telecommunications providers maintain a range of ways for consumers to contact them and manage their accounts. Issues around digital exclusion due to affordability are addressed below.

Affordability and social tariffs

Affordability is a key issue for consumers who are experiencing cost of living pressures associated with higher than average inflation figures. Ofcom’s Communications Affordability Tracker shows that these pressures have resulted in 26% of consumers taking actions to address affordability concerns: 12% made changes to a service, 10% reduced spend elsewhere, 7% cancelled a service and 4% missed a payment.[131] Of those consumers who experienced communications affordability issues, 59% also reported affordability issues with other household costs, including food (36%), clothes (25%), council tax (25%), gas/electricity (36%), an existing debt (27%) and travel costs (37%).

The reported actions taken by consumers varied depending on the type of service consumed.[132] Just 3% of consumers reported taking action to address affordability for fixed-line telephone or landline services. For fixed-line broadband services 6% reported taking action, for mobile telephone services 8% took action, while for pay TV and for on-demand TV services, 12% took action. This cascading scale of action may reflect the extent to which consumers view certain services as essential or discretionary.

Social tariffs are often suggested as a potential solution to affordability issues faced by telecommunications consumers.[133] These are cheaper or low-cost fixed-line broadband and mobile telephone packages offered by telecommunications providers to consumers claiming Universal Credit and other benefits to help them to afford their telecommunications services.

The availability of social tariffs has increased, with the number of social tariff options for fixed-line broadband offered by telecommunications providers rising from three in 2020, to more than 30 by December 2025.[134]

In addition, more people are taking up social tariffs, with 532,000 consumers making use of a fixed-line or mobile broadband tariff in June 2025, representing a significant increase in the number of consumers taking up these tariffs from around 55,000 in January 2022.[135]

Overall take-up, however, remains relatively low, and there are low levels of consumer awareness about the availability and eligibility criteria for social tariffs. Ofcom estimates that as of April 2026, 35% of consumers eligible for social tariffs are aware of them (34% were aware for fixed-line broadband specifically and 18% for mobile telephone social tariffs).[136] Overall, around two thirds (65%) of those consumers eligible for social tariffs were unaware of them.[137]

Ofcom figures from April 2026 show that the largest proportion of people first heard of broadband social tariffs through social media and from friends and family (29%), followed by online searching (13%), television (10%), social media (9%) and from a telecommunications provider (8%).[138]

Citizens Advice has examined ways to address the low take-up of social tariffs in the UK, making a number of recommendations to increase awareness and take-up, including proposing voucher schemes, targeted awareness campaigns, increasing visibility of provider offers and suggested changes to the eligibility criteria and services included in such tariffs.[139]

The UK Government’s Digital Action Plan notes that while the price of broadband and mobile services has fallen in real terms, and broadband and mobile social tariffs offer a safety net for those struggling with their bills, for many on very low incomes the price of connectivity remains too high.[140] Ofcom’s research has found that 7% of fixed broadband consumers and 5% of those with a mobile phone found it difficult to afford their service in October 2025. Between 0.6% and 0.7% of fixed telecoms customers and 1.0% and 1.1% of mobile contracts had missed two or more regular payments between July 2024 and June 2025.[141]

Under the UK Government’s Telecoms Consumer Charter, providers have committed to ensuring available social tariffs, available to consumer on means tested benefits, are easy to find and signposted to eligible customers. This signposting will be through regular communications, including, for example, in their ECNs, provider websites and app menus, as well as customer service scripts, ensuring they are easy to locate, understand and take-up. The UK Government encourages more providers to offer social tariffs where they are able to do so.[142]

Providers have also committed to supporting all customers who are facing financial difficulty by offering practical support such as the ability to move to cheaper packages without charge or penalty or manageable payment plans.[143]

While the price of broadband and mobile services has fallen in real terms, and social tariffs offer a safety net for those struggling with their bills, for many on very low incomes the price of connectivity still remains too high. Consumer Scotland notes the longstanding connections between poverty and digital exclusion. We recommend that the UK Government and Ofcom:

• Continue to work with providers to ensure prominent placement of social tariff offers in a range of communication tools including ECNs, websites and apps.
• Monitor take up of social tariffs and consider whether their makeup and the allowances included reflect what consumers need to undertake work, engage socially and access public services. Consider what further measures can be taken to raise awareness of social tariffs by consumers. Consider what measures can be taken to make the process of moving to a social tariff easier for consumers, whether by automating processes, increasing channels for enquiries, or otherwise supporting consumers to navigate processes
• Take prompt action to zero rate essential public services websites so that consumers can access these without needing data

In addition, the Scottish Government should

• Work with providers, local authorities, third sector partners and the UK Government to boost affordable access to devices and access to affordable (and where necessary free) data
• Ensure that affordability and access issues are addressed as part of its digital action plan and strategy

Conclusions

The telecommunications market plays a vital role in enabling consumers in Scotland to access an extensive range of goods, services and markets, including healthcare, social security, banking, education, retail, social networks and entertainment. Access to these markets is critical to consumers’ wellbeing, to enabling their active participation in the economy and to supporting citizens’ access to vital public services.

Over the past two decades there has been extensive rollout of a wide range of fixed and mobile technologies across Scotland. This has transformed how consumers access and interact with services and many consumers now benefit from access to high speed, reliable and affordable telecommunications services.

However, consumers in Scotland can face a range of challenges with accessing telecoms services. While there has been recent improvement, some consumers in Scotland can face geographic disadvantages compared to those in other parts of the UK, with many rural and island communities in Scotland experiencing particularly significant challenges across both broadband and mobile markets. Other consumers can struggle to access digital markets, or to effectively maximise the benefits and mitigate the risks of doing so, due to a combination of costs, confidence and skills.

Ongoing action is needed to tackle connectivity gaps, improve access, and boost digital inclusion, reducing the digital divide and allowing consumers in Scotland to participate fully in an increasingly digital society and economy.

Through our assessment we identify the following as key areas for future action:

• While the rollout of broadband services continues to gather pace, gigabit and Superfast coverage continues to lag significantly in rural and island areas of Scotland and presents a clear risk of digital inequality. The gap in gigabit coverage for rural Scotland is particularly pronounced. There also remain around 10,000 premises in Scotland who still cannot receive even a “decent” broadband service using either fixed line or fixed wireless access technology.
• 5G mobile coverage also lags behind in Scotland, compared with other UK nations. In addition, the retirement of legacy technology such as the 2G and 3G mobile phone networks and older generation landlines poses challenges for both providers and consumers. Further efforts are required to make sure consumers understand what is changing and are supported to take any necessary action.
• Work is required by providers and regulators to ensure that technology supports consumers’ needs for uninterrupted access to calling and messaging services, connected health care services and critical public services. There is also scope to improve the ways in which the sector responds to the needs of consumers in vulnerable circumstances, particularly in relation to issues around priority services, appropriate data sharing and disclosure of consumer needs. Improving everyday lives for consumers depends on them being able to access comprehensive, resilient and reliable telecommunications networks.
• Consumers in rural or island areas can face increased risks due to a combination of the frequency and length of power cuts, poorer than average mobile phone network connectivity and capacity, the migration to digital landlines, a lack of resilience in local telecoms networks and the impacts of the 2G and 3G switch-off. It may be challenging for providers to contact consumers directly, raising the likelihood that more direct UK Government action, in coordination with providers, will be needed.
• In addition to geographic issues, competitive conditions within the telecommunications markets differ across the UK. With fewer providers operating in more rural areas, consumers may find it harder to switch and to achieve best value for their services. This makes an even greater case for effective consumer protection against poor service, particularly for those consumers for whom switching will not be an option. Ensuring transparency means allowing consumers to understand their usage and needs so they can navigate increasingly complex purchase options. It is also important that all consumers can access services of appropriate quality and that they can easily resolve issues where they do occur.
• Affordability issues can also act a barrier to consumers accessing telecommunications services. There are longstanding connections between poverty and digital exclusion. Although social tariffs exist in telecommunications markets, these are hampered by a lack of consumer awareness and relatively low take-up levels. Even social tariffs may be too expensive for some consumers and action is needed to ensure consumers can access devices, have the skills and confidence to use them safely and can get online affordably.
• The Public Service Reform agenda in Scotland offers opportunities to address access to public services by digital means. Taking full advantage of this will require user centred design, rigorous impact assessment and building in ways of supporting consumers to access digital services where needed.

Recommendations

We set out below our recommendations to address the issues identified through our analysis and improve equitable access to telecommunications services for consumers in Scotland.

Connectivity

Recommendation 1: Consumer Scotland recommends that Ofcom and the UK Government ensure that the Broadband USO review commences promptly in 2026. The review should:

• commit to raising the speeds specified in the USO to at least Superfast level
• take a technology agnostic approach to how the USO can be fulfilled, drawing on the possibilities offered by the rollout of satellite technology, standalone 5G and 6G mobile services
• continue to include reference to affordability measures as part of the USO criteria to ensure services are accessible to as many consumers as possible and to prevent detriment

Recommendation 2: Ofcom should:

• continue to monitor access to any revised USO, reporting on coverage by nation, and local and constituency areas, and with coverage also broken down by rural and urban areas
• extend consumer facing information to include information on when various technologies are expected to be available to consumers, based on their postcodes. This information should draw together work by providers and by both governments to provide a more comprehensive picture than currently exists, across a wider range of technologies and expressed in more accessible ways

Recommendation 3: The Scottish Government should refresh Scotland’s Full Fibre Charter in the light of any revised USO obligation and planned network deployments by providers, clearly identifying the actions it will take to improve connectivity, whether alone or working with partners.

Recommendation 4: Following the publication of the most recent work on planned network deployments, and the conclusion of the Mobile Markets Review, Ofcom should establish nations-level benchmarks for mobile performance to accompany its proposed 90% UK benchmark to ensure delivery of significant performance improvement in Scotland and the other UK nations. The Scottish and UK Governments should work together to identify and agree priority areas for further investment both by providers and governments to meet these benchmarks.

Legacy technology and network resilience issues

Recommendation 5: In the lead up to the 2G switch-off, Ofcom should undertake active monitoring of consumer awareness of the changes. Where awareness levels are low this should trigger further, government backed, communication measures both directly to consumers and through trusted intermediaries to raise awareness, as has been the case with digital calling.

Recommendation 6: Ofcom should set out a detailed timetable for concluding its engagement with providers and power distribution networks to assess which sites are most at risk of continuing outages. Following this the regulator should set out a plan of action, by the end of 2026, to ensure that the effects of outages on consumers can be reduced.

Consumer Protection

Recommendation 7: Ofcom should:

• undertake further research on consumer understanding of pricing practices and other key contractual provisions
• monitor switching, price and other recent reforms to ensure that they are effective in protecting consumer interests and publicly report on the actions they will take to ensure this
• consider how to give consumers more information about their usage so that they have more control when negotiating contracts
• consider whether assisted digital services could help consumers who are not currently engaged in switching or who have trouble resolving issues with providers

Recommendation 8: Ofcom should urgently refresh its guidance on supporting consumers in vulnerable circumstances. This guidance should build on the Charters developed by the UK Government and:

• set out protocols in relation to provider practices on issues such as pricing and contractual terms and debt recovery practices
• define Ofcom’s approach to how consumers can be supported to share relevant information about their needs with providers and Ofcom’s expectations of how providers will respond to these disclosures
• take account of best practice in sectors such as energy and financial services.

Recommendation 9: Providers should be required to provide consumers with advice on their usage and on the best available deal across a wider range of communication channels, including any app or website accounts, to ensure the contractual process better meets consumer needs.

Inclusion and Affordability

Recommendation 10: The Scottish Government should address issues around access to services in its work on digital inclusion and on public service reform. It should:

• ensure that reform of public services delivery is rigorously impact assessed and user tested to ensure inclusive design
• ensure that provision of assistance to access digital public services is built in to service design from the start to avoid exclusion from services
• work with Ofcom and the UK Government to help consumers improve digital skills which can boost consumer confidence in using online services

Recommendation 11: We recommend that the UK Government and Ofcom:

• continue to work with providers to ensure prominent placement of social tariff offers in a range of communication tools including ECNs, websites and apps
• monitor take up of social tariffs consider whether their makeup and the allowances included reflect what consumers need to undertake work, engage socially and access public services. It should also consider what further measures can be taken to raise consumer awareness of social tariffs. It should also consider what measures can be taken to make the process of moving to a social tariff easier for consumers, whether by automating processes, increasing channels for enquiries, or otherwise supporting consumers to navigate processes.
• take action to zero rate essential public services websites so that consumers can access these without the need for data

Recommendation 12: The Scottish Government should:

• work with providers, local authorities, third sector partners and the UK Government to boost affordable access to devices and access to affordable (and where necessary free) data
• ensure that affordability and access issues are addressed as part of its digital action plan and strategy

[1] Ofcom (2024) Online Nation 2024. Available at: https://www.ofcom.org.uk/siteassets/resources/documents/research-and-data/online-research/online-nation/2024/online-nation-2024-report.pdf?v=386238