Navigating The New OFCOM Rules For UK Businesses Calling From Offshore

New OFCOM regulations designed to hamper the ability of overseas spam callers to ‘spoof’ UK phone numbers could also impact legitimate offshore and outsourced contact centres.

From 29 January 2025, stricter guidelines on Calling Line Identification (CLI) will come into force to combat the rising tide of scam calls plaguing UK consumers.

UK telecom operators will be required to identify and block calls originating outside the UK, which present as UK numbers, except in limited legitimate use cases.

 

Why Is OFCOM Doing This?

Spam calls to consumers are one of the major sources of fraud the world over. According to a survey by OFCOM, 48% of UK landline users received at least one suspicious call in the previous 3 months.

Some people reported receiving two fraudulent calls per day, with the over 75s being particularly vulnerable to this kind of scam.

Phone scams are thought to cost their victims an average loss of around £400. In the US, consumer losses are estimated to amount to nearly $30 billion annually. The UK, being the fourth most-spammed country in the world, will not be too far behind.

 

What is the scale of the spam calling crime?

Spam callers aim to trick their victims into handing over personal or payment details or making a payment to an illegitimate recipient by posing as a trusted institution or company.

The most common financial scam is Authorised Push Payment (APP) fraud, where the scammer deceives people into transferring funds to them. While 76% of APP cases use online methods of communication, and only 16% use the phone, phone scams actually account for 43% of the total APP losses suffered by consumers.

It shows the trust we place in the phone when we believe that a legitimate institution with whom we have an existing relationship is contacting us.

 

What action is OFCOM taking?

OFCOM’s new guidelines are designed to close a loophole that allowed scammers to exploit international calls displaying UK numbers. This builds on previous measures introduced in May 2023 that blocked international calls spoofing UK numbers as their Network Number. Now, OFCOM is extending these protections to cover Presentation Numbers, the number actually displayed to the person receiving the call.

The key change is that communications providers will now be required to block calls from outside the UK and Crown Dependencies that use a UK number as their Presentation Number, except in specific legitimate circumstances.

If your offshore call centre currently uses a UK number to call UK customers, you’ll need to review your practices and ensure they meet OFCOM’s requirements.

 

What Are the Legitimate Use Cases?

OFCOM recognises legitimate reasons for calls from outside the UK to display a UK number. These include:

• Calls from UK or Crown Dependency mobile users roaming abroad and calling back to UK numbers: This ensures that genuine calls from UK residents travelling overseas are not blocked.
• Calls to a mobile user who is roaming in the UK or Crown Dependencies: These calls use specific number ranges that identify them as legitimate roaming traffic.
• Calls originating on a UK or Crown Dependency network, routed outside those networks, and then re-entering through a UK or Crown Dependency network: This covers scenarios where businesses use UK-based cloud services or have complex call routing arrangements.
• Calls made by a UK or customer but originating from a non-UK network such as overseas nodes of cloud services: This is the most relevant exception for businesses with offshore call centres. It allows calls to display a UK Presentation Number if they can demonstrate that the call is being made on behalf of a UK customer.

 

What Do I Need to Do to Stay Compliant?

Businesses that originate calls offshore to UK consumers must demonstrate to their UK carriers that they are legitimate. They will also need to provide their carrier and the recipient of the call with:

• A valid UK phone number designated as ‘Telephone Number available for Allocation’ in the National Telephone Numbering Plan.
• A number that the recipient can dial should they wish to make a return or follow-up call.
• A number that uniquely identifies the caller, which has been assigned to them by their carrier or which they have been granted permission to use by the individual or organisation assigned the number.

To comply with all those conditions, some businesses may need to route their calls differently, potentially through direct connections with UK networks rather than cheaper international routes. While this might increase costs slightly, it’s necessary before consumers lose all trust in the legitimacy of anyone calling or texting them.

 

How do I transition?

Implementing these changes requires careful coordination between your contact centre, IT team, offshore or outsourced operation (if you have any), telecom providers, and potentially cloud service providers. Steps to consider include:

1. Review Your CLI Usage: Work closely with your communications provider to ensure that your call centre only uses UK CLI for legitimate calls that fall under one of OFCOM’s exceptions. Ensure the phone numbers you use are valid, dialable and uniquely identify you – and that you have the appropriate permissions to use them. This may involve providing evidence to demonstrate that any of your calls originating abroad or via the cloud are being made on behalf of a UK entity.
2. Implement Proper Call Routing: If your call centre uses cloud services or complex routing arrangements, ensure they are set up to comply with OFCOM’s guidelines. You may need to adjust your routing to ensure that calls using UK CLI are directly connected to a UK network to avoid being blocked. Consult with your vendor if you use a cloud contact centre platform, particularly one hosted outside the UK.
3. Train Your People: Ensure your contact centre and IT colleagues are familiar with the new OFCOM regulations and understand the importance of compliance. Make sure they know what the legitimate use cases are and how to avoid any practices that could result in calls getting blocked.
4. Audit and Monitor Compliance: Regularly review your call centre’s practices to ensure compliance with the new OFCOM guidelines. This may involve working with your communications provider or cloud vendor to monitor call traffic and identify potential issues.
5. Engage with OFCOM: OFCOM plans a stakeholder engagement programme to support businesses during implementation. Take advantage of these opportunities to seek clarification and guidance on specific scenarios relevant to your operations.

 

What about offshore and outsourced contact centres?

If your business has contact centre colleagues working offshore or you use an offshore outsourced contact centre, you will need to check that you comply. If another company or offshore entity (whether owned by you or not) is making calls on your behalf to UK consumers, remember that you, the UK company, remain ultimately responsible for ensuring compliance with OFCOM regulations. You must work closely with your outsourced provider to ensure their practices align with the new guidelines. You should also review your contracts with outsourcers to ensure they include clear clauses on compliance with UK regulations, and consider conducting regular audits to monitor compliance. You may also need to register valid and dialable UK phone numbers and then provide these to your partner to use.

If you are a BPO (Business Process Outsourcer) or offshore operator, it is incumbent upon you to ensure your operations are compliant. Advise your clients on the steps you are taking and the steps they must take before 29^th January 2025.

 

What happens if I don’t comply?

Failure to comply with the new OFCOM guidelines could mean your calls to UK consumers get blocked by UK carriers. Inevitably, this would disrupt customer communications, potentially harm your business or cost you sales. OFCOM has a lot of powers at its disposal and can take action against companies that breach their regulations, including imposing financial penalties.

While the changes required could be moderately expensive in some cases, there is an upside to consider. Due to the prevalence of spam calls, consumers are increasingly wary of answering unknown calls – or, in some cases, any calls unless they’re from friends and family. Proving your legitimacy could become a crucial competitive advantage. With fewer scam calls making it through to customers, the calls made by legitimate businesses face less competition for attention and less distrust, potentially improving connection rates.

Remember, this isn’t just about regulatory compliance – it’s about maintaining customer trust in an increasingly suspicious world. Businesses that get this right will build themselves a competitive advantage by ensuring they can access their customers on their phones.

Don’t wait for your competitors to figure this out first. We recommend beginning your compliance journey today and turning this regulatory challenge into an opportunity to strengthen your customer relationships.