Thursday, April 18, 2024
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    EDITOR’s BLOG 18-09-15 That 120 day rule

    Hello and Happy Friday! Or not if you are billing for subscription services. As we got to press, the network operators are, in the words of one telemedia veteran, “not so much using a sledge hammer to crack a walnut, but using a wrecking ball to crush a chick pea” by introducing a 120 days rule to subscription services that will see anyone running these services have to reregister and verify anyone who pays for a subscription then doesn’t ‘interact’ with that service for any 120 period.

    According to missives issued by all the networks and the PFI Management Group, from 1 September 2015, to quote Three (although the message from all the networks was in essence the same): “Merchant Services where consumers are inactive for a period of 120 consecutive days must be manually unsubscribed and removed from any further billing applicable to that service only. For the avoidance of doubt, ‘inactive’ means the subscriber has not downloaded content, or sent any MO SMS to the service provider. Subscribers who browse a service mobile or web-site will be considered to be ‘active’.”

    The missives go on to exempt push services, such as football scores, from the ruling and that this has to be dealt with immediately.

    Perhaps more worrying is that the operators are also demanding to see interactivity logs from 19 October to double check.

    Provenance of the rule is unclear, but it seems to have been introduced because of a few rogue services in the adult sector and a number of complaints from consumers who didn’t know what they were signing up for.

    And just when charge to mobile was getting going too.

    The rule has caused indignation amongst the telemedia community as it seems to be a blanket ruling across all services, with no consideration of whether its practical or not, not on how to effectively police it.

    One of the biggest issues with it is that the onus is on the L2 to prove that interaction has (or hasn’t) taken place in the that period and to share that proof with the MNOs. This would mean sharing interaction logs with the MNOs, which the L2s can’t legally do without the permission of the consumer.

    This would require a mass rewrite of services, create a new minefield of Ts and Cs to get through and ultimately could be pointless. As our squashed chick pea enthusiast puts it: “They [the MNOs]are simply saying if you can’t prove interaction between the subscriber and the service you must remove them…. Can Motorcycle Monthly provide robust verification that I have read the mag they send me each month ?  No they can’t.”

    The move comes just as many telemedia companies are starting to make headway in selling the charge to mobile concept to many verticals to bill for subscription services. This is quite a set back and could prove ruinous for many providers.

    Some in the industry see it as the final nail in the coffin, with the networks now making it impossible for them to run most services and tearing the heart out of the subscriptions market.

    Others aren’t quite so concerned, believing that with business moving to more mainstream companies will see most users of new subs services interacting within the time frame and it all being well.

    They still face the burden of having to prove this interaction, which has opened a huge can of worms.

    There is also the fact that all the other work being done on new PSMS flows and Payforit rules, as well as additional customer service work by L2s would make the reasons for this 120 day rule disappear anyway in a matter of months if not weeks.

    Of course, will be looking in much more depth into this issue in the coming weeks and it will no doubt be one of the hot talking points at World Telemedia in Prague 10-12 November. We want to hear what you thing, so get in touch.


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