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Ofcom Compliance Checklist 2026

Ofcom compliance checklist for UK telecom providers. All 27 General Conditions with deadlines.

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Step-by-step guide to all 27 General Conditions for UK telecom providers and resellers.

Quick answer: This checklist walks UK telecom providers through Ofcom's General Conditions, one by one, with the practical step for each and the deadlines to plan around in 2026.

Updated February 2026 | Reference Document

What You Learn

  • ✓ Ofcom compliance requirements
  • ✓ Self-assessment checklist
  • ✓ Common compliance gaps
  • ✓ Enforcement triggers

Who It's For

  • • UK service providers
  • • Compliance managers
  • • Business owners
  • • Legal teams
← Back to UK Telecom Compliance Guide
Bottom Line Up Front

UK telecom providers must comply with 27 Ofcom General Conditions. For resellers, 6 conditions are critical: GC C1 (fraud), GC C2 (999 access), GC C3 (CLI), GC C5 (directories), GC C7 (contracts), GC C8 (switching). Non-compliance penalties reach 10% of turnover. Registration is free and takes 1-3 days.

Quick Reference

Key Numbers

Total General Conditions27
Conditions applicable to resellers6-8 (depending on services)
Ofcom registration fee£0 (free)
Registration processing time1-3 business days
Maximum penalty (serious breach)10% of relevant turnover
Number porting deadline1 working day
Contract cooling-off period14 days
Complaint resolution deadline8 weeks

2026 Compliance Deadlines

1 Jan 2026
CLI authentication (STIR/SHAKEN) requirements for large providers
1 Apr 2026
One Touch Switch expansion to business services
Ongoing
Annual ADR scheme membership renewal
Ongoing
Quarterly fraud reporting (providers with >100k subscribers)

Step-by-Step Compliance Checklist

Phase 1: Registration (Day 1)

  1. 1
    Submit Ofcom Notification
    Complete the online notification form at ofcom.org.uk. Required before providing any electronic communications services.
    Cost: Free | Time: 15 minutes | Processing: 1-3 days
  2. 2
    Register with ADR Scheme
    Join either Ombudsman Services: Communications or CEDR. Required for residential customers.
    Cost: £200-500/year (based on size) | Time: 1-2 weeks
  3. 3
    Register with ICO
    Data protection registration at ico.org.uk. Required if processing personal data.
    Cost: £40-2,900/year (based on size) | Time: Immediate online

Phase 2: Contract Documentation (Week 1-2)

  1. 4
    Create GC C7 Compliant Contracts
    Contracts must include: minimum term, monthly price, included allowances, early termination charges, complaint procedure, ADR scheme details, switching information.
    Reference: Ofcom General Conditions of Entitlement
  2. 5
    Prepare Pre-Contract Information
    Create standardised information document showing: service description, pricing, contract length, what happens at end of contract, how to switch away.
    Required: Before customer signs | Format: Durable medium (email/paper)
  3. 6
    Document Cooling-Off Procedure
    14-day cancellation right under Consumer Contracts Regulations 2013. Must inform customer at point of sale and in contract.
    Deadline: Customer can cancel within 14 days without penalty

Phase 3: Operational Systems (Week 2-4)

  1. 7
    Implement GC C1 Fraud Prevention
    Deploy: traffic monitoring, destination blacklists, credit limits, velocity checks. Document incident response procedure.
    Critical: Most common enforcement area | See: GC C1 Fraud Guide
  2. 8
    Verify 999 Access (GC C2)
    All voice services must connect to emergency services. If using VoIP, ensure fallback for power/internet outages is documented.
    Test: Quarterly testing recommended
  3. 9
    Configure CLI Display (GC C3)
    Outbound calls must display valid CLI. Implement CLI validation for customer-provided numbers.
    New: STIR/SHAKEN requirements from 2026 for large providers
  4. 10
    Set Up Switching Procedures (GC C8)
    Implement One Touch Switch process. Customer initiates switch with new provider; you must release within 1 working day.
    Penalty: Active blocking of switches is a serious breach

Phase 4: Ongoing Compliance

  1. 11
    Maintain Complaint Handling
    Resolve complaints within 8 weeks or issue deadlock letter. Log all complaints. ADR referral for unresolved disputes.
    Record retention: 12 months minimum
  2. 12
    Annual Compliance Review
    Review contract terms, update for Ofcom changes, verify ADR membership current, test fraud controls, update staff training.
    Schedule: January recommended (before regulatory year)

General Conditions by Category

ConditionTopicApplies ToPriority
GC A1-A4Network access & interconnectionNetwork operators-
GC B1-B4Number portabilityAll providersHigh
GC C1Fraud & misuse preventionAll providersCritical
GC C2Emergency call access (999)Voice providersCritical
GC C3CLI presentationVoice providersHigh
GC C4Public payphonesPayphone operators-
GC C5Directory enquiriesVoice providersMedium
GC C6Facilitating number portabilityAll providersHigh
GC C7Contract requirementsResidential providersCritical
GC C8SwitchingAll providersCritical

Enforcement Actions: Recent Examples

Penalty Reference Data

Recent Ofcom enforcement actions demonstrate the financial risk of non-compliance:

  • O2, 2023: £13.3 million fine for overcharging customers leaving contracts
  • EE, 2019: £2.7 million for billing errors affecting 40,000 customers
  • Shell Energy, 2022: £1.4 million for switching failures
  • iD Mobile, 2021: £1.0 million for complaint handling failures

Common triggers: Contract billing errors, switching obstruction, complaint handling failures, CLI spoofing facilitation.

Required Documentation Checklist

DocumentPurposeRetention
Customer contractsProof of agreed terms6 years after end
Pre-contract informationProof of disclosure6 years after end
Cooling-off acknowledgementsProof rights explained6 years after end
Complaint logsADR compliance12 months minimum
Fraud incident reportsGC C1 compliance3 years
Switching recordsGC C8 compliance12 months
Voice recordings (sales)Verbal contract proof6 years
CDR recordsFraud detection12 months minimum

Related Guides

UK Telecom Compliance Overview

Complete framework covering all regulatory requirements.

GC C1 Fraud Prevention

AIT detection, IRSF prevention, fraud monitoring.

All 27 General Conditions

Detailed breakdown of each condition.

PECR Compliance

Marketing consent, TPS, cookie requirements.

Related Pages

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How long does Ofcom registration take?

Ofcom registration takes 1-3 business days. Submit the online notification form before providing any electronic communications services. There is no fee for registration.

What are the penalties for Ofcom non-compliance?

Ofcom can impose fines up to 10% of relevant turnover for serious breaches. For persistent non-compliance, Ofcom can suspend or revoke provider authorisation. Individual enforcement actions have reached £2.7 million (EE, 2019) and £13.3 million (O2, 2023).

Which Ofcom General Conditions apply to telecom resellers?

Telecom resellers must comply with GC C1 (fraud prevention), GC C2 (emergency call access), GC C3 (CLI display), GC C5 (directory services), GC C7 (contracts), and GC C8 (switching). Additional conditions may apply depending on services offered.

How often should compliance be reviewed?

Annual compliance reviews are recommended minimum. Ofcom typically updates General Conditions 1-2 times per year. Major reviews occurred in 2022 (One Touch Switch) and 2025 (CLI authentication requirements).