Digital inclusion, resilience and adoption take greater prominence in the new SSP, while there are less than subtle hints for Ofcom’s expected regulation of Openreach
Ofcom must take account of the SSP when carrying out regulatory duties
On 21 July 2025, the UK Government launched a two-month consultation on its strategic priorities and desired outcomes for telecoms and spectrum. They are set out within a proposed Statement of Strategic Priorities (SSP), which will update the current – and original – version from 2019 once it is laid in Parliament for 40 days and subsequently designated by the Secretary of State. The new SSP will provide steers that reflect the Government’s ambitions and agenda (e.g. unlocking economic growth, promoting digital inclusion and boosting investment, innovation and productivity), which Ofcom must have regard to when exercising its regulatory functions. For the telecoms sector, the draft SSP includes four areas through which to drive growth: i) world-class fixed and mobile networks; ii) spectrum access; iii) competitive retail markets; and iv) secure and resilient infrastructure.
Clear expectations that regulation should help drive competition and investment
The most substantial section of the proposed SSP is dedicated to digital infrastructure, particularly fixed broadband. While recognising the growth in access to gigabit-capable networks over recent years, there is an evident steer to Ofcom to closely monitor Openreach’s wholesale terms and pricing, and to prevent it offering commercial arrangements that would harm competition and investment – two outcomes the Government considers more important than reducing retail prices in the short-term. The draft SSP “expects” Ofcom to take a cautious approach when considering whether to remove regulation, so that competition can be established and then maintained over time, while making fairly concise directions as to the regulators’ support for business connectivity, universal access and legacy network switch-offs. Compared to the current SSP, the draft feels considerably stronger in urging Ofcom to: proactively monitor whether Openreach is providing physical infrastructure access (PIA) according to the no undue discrimination principle; take action if Openreach is found not to be compliant with its regulatory obligations and ensure any changes to the PIA framework via the Telecoms Access Review (TAR) are proportionate, evidence-based and again support competition and investment. The Government states that it wants greater transparency about how Ofcom calculates PIA prices, which should be based on a fair and reasonable pricing model, and take account of responses submitted during the TAR process, some of which have argued that Openreach is charging external customers more for the use of its ducts and poles than it charges itself.
Notably, there is discussion of Ofcom’s role in the take-up of gigabit broadband, with the SSP encouraging new reporting from the regulator on adoption every six months alongside ongoing monitoring of the One Touch Switch (OTS) process. In contrast, the current SSP makes only a passing reference to adoption, placing the onus on industry to promote fibre to consumers. With respect to mobile, there is a clear shift in priorities from increasing coverage and tackling not-spots (which would have been partly addressed by commercial investment and the Shared Rural Network (SRN) project) to ensuring effective competition and monitoring 5G investments – things Ofcom will be doing anyway in light of VodafoneThree’s merger commitments. Further additions to the draft SSP include:
Ofcom’s ‘Map Your Mobile’ coverage checker: The regulator has been asked to continue improving the quality of its coverage reporting on mobile network availability and quality (e.g. by providing coverage and performance data on a per county and per constituency basis, and by reporting on standalone 5G), indicating that the Government does not consider to tool to be fit for purpose despite only being launched one month ago; and
Net neutrality: While any changes to the Open Internet Access Regulations – as has been sought by some operators – would involve amending primary legislation, Ofcom should inform the Government of the impacts of its revised net neutrality guidelines and whether it considers any other adjustments are required that would help foster innovation by ISPs and the wider digital ecosystem.
The proposed SSP advocates greater spectrum sharing, while ensuring frequencies are available to meet the needs of the emergency services, the public and space sectors, and PMSE licensees
Regarding spectrum, the proposed SSP praises the “pioneering step” taken by Ofcom to introduce a spectrum sharing framework in 2019, which included making the 3.8-4.2GHz band available for shared access licences. To that end, while the draft SSP makes no mention of using spectrum as a tool to improve mobile coverage (unlike in the current version), the regulator continues to be encouraged to promote flexible spectrum sharing models, as well as to ensure sufficient spectrum is available for the public sector in order to support strategic government priorities and deliver critical services. The SSP calls on Ofcom to ensure the spectrum needs of the emergency services, the space sector and programme making and special events (PMSE) licensees are met, and to keep engaging with the Government on the future of digital terrestrial television (DTT), ensuring appropriate consideration is given to both the potential value of the spectrum and the need to continue serving audiences.
Ofcom should leverage its position to drive digital inclusion and work with operators to improve the customer experience, especially for vulnerable groups
At the retail level, the Government states that it supports Ofcom’s shift in focus towards monitoring and evaluating consumer-oriented interventions (presumably away from introducing any new ones), and would welcome evaluation of their overall impact and costs. It encourages further collaboration between the regulator and industry to address specific customer care concerns and to improve consumer confidence with new and emerging broadband and mobile providers (particularly in respect of vulnerable end users), as well as to tackle network vulnerabilities that can lead to scams. In light of Ofcom’s duty to monitor the affordability of telecoms services, the Government urges it to establish a regular and consistent reporting cycle, able to highlight trends over time. Most interestingly, the proposed SSP recommends Ofcom uses its “significant influence” to consider how it can best contribute to addressing digital exclusion, including collaboration with other regulators. This issue was not mentioned in the 2019 SSP, reflecting its rise up the political agenda, which has manifested in the Digital Inclusion Action Plan that states that 1.6m people in the UK are currently living offline. Though digital inclusion is affected by more than access and affordability barriers, which may appear more likely to be within Ofcom’s scope of influence, the Government sees the regulator as well-positioned to promote safe digital participation.
Resilience now appears a greater concern than security
Security and resilience occupied a distinct, yet brief, section in the 2019 SSP, focusing largely on ways to minimise risks to the UK’s telecoms supply chain. While this remains important and the draft acknowledges the obligations imposed on Ofcom following the introduction of new security legislation in 2021 and 2022, it appears geared more towards resilience, with the Government highlighting two main priorities in this area:
Power resilience: Ofcom should work closely with telecoms providers, the Government and the energy sector on collaborative efforts that reduce the likelihood of power cuts leading to a loss of service and reduce the impact of any loss of service to consumers. However, this does not seem to represent a significant shift in responsibility away from operators, with Ofcom suggested to examine what resilience measures in the mobile access network may be appropriate and proportionate; and
Incident reporting and publication of outage data: Ofcom should ensure that satellite connectivity enables access to the emergency services in the same way as fixed and mobile networks, and continue to support the Government’s duties under the Climate Change Act 2008, including by providing resilience standards and guidance to telecoms providers.
