RD332 - ETNO Reflection document - Comments on the Draft ECC Report 155 on “Number Portability Procedures”

Number portability is a fundamental element to consolidate competition on the market. ETNO urges Member States to take a very cautious approach when transposing the Directives into national legislation.Too far-reaching requirements which could be unrealistic for operators and unreliable for customers should be avoided. The practical implementation and the duration of service interruption are critical issues.Consumers should not be faced with loss of service beyond one day or preferably less.

  • Number portability is a fundamental element to consolidate competition on the market. ETNO urges Member States to take a very cautious approach when transposing the Directives into national legislation.
  • Too far-reaching requirements which could be unrealistic for operators and unreliable for customers should be avoided. The practical implementation and the duration of service interruption are critical issues.
  • Consumers should not be faced with loss of service beyond one day or preferably less. ETNO recalls the need to distinguish residential from business customers, due to specific complexity of number portability on complex installations for business customers.
  • ETNO welcomes the opportunity to comment on the Draft ECC Report 155 and its in-depth exhaustive analysis of the provisions in the revised Regulatory Framework regarding Number Portability.
  • Indeed, number portability is a fundamental element to consolidate competition on the market and a correct implementation is the best means to give confidence to consumers. On this background, ETNO will urge Member States to take a very cautious approach when transposing the Directives into national legislation.
  • It is of utmost importance not to impose too far-reaching requirements which could be unrealistic for operators and unreliable for customers. In ETNO point of view, the practical implementation, the details of the process as well as the duration of service interruption are more critical issues which determine the time length for portability.
  • ETNO believes that the right approach will be to ensure that the requirements should guarantee that consumers are not faced with loss of service beyond one day or preferably less. ETNO will also recall the need to distinguish residential and business customers due to a specific complexity of number portability on complex installations for business customers.