Billing and Disputed Charges

Accessible Billing

This video provides information on receiving accessible billing from your Service Provider.

Methods of Billing

Service providers may issue alternative billing mediums to their customers if they can guarantee that the customer can access and use the alternative medium. If they cannot guarantee this, they will issue a paper bill. Alternative billing mediums can include a bill being provided to you electronically (by e mail) or on-line. If a customer cannot access the alternative billing medium, (for example because the customer does not have broadband access or cannot use an on-line service), the service provider must issue the customer with paper bills free-of-charge.

For an online bill, the service provider must let their customer know when the bill is available online. These alerts (especially if being sent by SMS) should be sent during appropriate (sociable) hours, and customers who do not want to receive such alerts should have the option to opt-out of receiving them in accordance with Data Protection legislation. Alerts must be separate to any direct marketing messages that may be sent in accordance with Data Protection legislation.

ComReg’s Decision – what has changed?

In June 2013, following a public consultation, ComReg issued a Decision in relation to providing bills to consumers of electronic communication services (ECS). Until now, there were different regulatory requirements in relation to billing in place for Service Providers, in some cases there were no requirements on certain providers in respect of bill itemisation or bill mediums (i.e. paper or electronic bill). For example, some providers could charge for a paper bill or for an itemised bill or switch their consumers to electronic billing without any requirements being fulfilled.

Without ComReg’s Decision consumer rights in respect of billing would not have been in place and guaranteed into the future for all electronic communications service providers.

To ensure consumers are protected in respect of billing, irrespective of who the service provider is, the consumer protection rules form part of the General Authorisation and standardise all electronic communications service (ECS) providers’ related obligations.

What are the rules?

The main rules introduced include:

• The provision of bills to post-paid consumers free-of-charge.
• The level of bill itemisation cannot be changed without the consumer’s consent. Also, the consumer can request a fully itemised or non-itemised bill.
• Pre-paid consumers (usually mobile) must be given access free of charge to their recent transaction history, upon request.
• Calls which are normally free-of-charge are not to be identified on consumer bills, for example 1800 XXX XXX numbers.
• Paper bills must be issued unless the service provider has verified that the consumer can access and use the alternative billing medium (such as electronic billing).
• Where service providers intend switching the customer to a billing medium that is not paper (including an electronic bill), in accordance with the rules, they must be provide certain information in advance to these customers to ensure that the customer can access and operate the electronic bill.
• If the customer is on electronic billing and subsequently notifies their provider that they cannot access their bill, bills must be provided in paper medium free-of-charge.  Once a consumer notifies their provider they cannot reasonably access their bill, bills must be provided in paper medium free-of-charge.
• Where bills are provided online (via the service providers website), service providers must notify consumers that the bills are available.

These are minimum protections, without which ComReg was concerned that consumers would not be able to access their bills or would have to pay for a bill that they could access.  For example, prior to ComReg’s Decision, some providers were able to charge for a paper bill (even if the customer needed it), or could switch their customers to electronic billing without any obligations or could charge for an itemised bill or for a transaction history for pre-paid customers.  In addition to fulfilling these minimum requirements, service providers may, within the regulatory requirements, give their customers additional choices and options in respect of billing.

The new conditions mean that service providers can only place their customers on an electronic bill if certain conditions are met. The conditions also allow customers to inform their service provider if they cannot access or use an alternative billing medium such as an electronic bill and in those cases, service providers must provide a paper bill to consumers free of charge.

The Response to Consultation and Decision document ComReg1352.pdf explains the above in more detail.

Disputed Charges

If you receive your bill and you believe that it is incorrect you should raise this immediately with your service provider as a complaint.  Please ask your service provider if they provide a complaint reference number for your reference as some service providers allocate individual complaint reference numbers. Please allow your service provider 10 working days to resolve the billing issue, if the matter is not resolved in a reasonable timeframe please contact ComReg with all the details of your billing complaint and we can review and escalate your complaint if appropriate directly with your service provider on your behalf.

Multiple Bills

A consumer may on occasion receive bills from two service providers for calls/line rental etc for the same period, this can happen if you have recently switched your service. Cancellation fees may be present on the bill. If a consumer is still in a fixed term contract with the first provider when s/he switches, s/he may be billed the package fee for the remainder of the contract period. The consumer should log a complaint with that service provider first, and depending on their response, may be advised to now log a complaint with the other provider.

Consumers should examine the bills closely to ensure that both bills are charging for duplicate services for the same period. (ie that one bill is not for line rental and the other for broadband, for example). If a consumer is unable to resolve we can escalate as appropriate.

First bill higher than expected

Your first bill will be slightly higher than other bills as you are paying for more than one month of usage. This is because your first bill covers the period from when your service is connected up until your first bill, as well as your price plan for the month ahead.

For example, if you had your installation appointment on the 24th of November and your first bill issues on the 5th of December, your bill will include a charge from the 24th of November to the 4th of December called part-period charges and credits. You would then pay a charge for your price plan for the month ahead (from the 5th onwards).

Billed outside your package/bundle

Many consumers bundle their telecoms services when possible (one bill for all services – home phone, mobile phone, broadband, TV). Generally these bundles provide consumers with a good price for all services which is subject to caps on calls, texts and data. If you use more calls, texts or data outside of your allocated allowance/bundle you will be charged at a much higher rate for this especially for data which is normally charged per megabyte.

You should always ensure that you know how to monitor your usage and always ask your provider are you notified when you reach the limit of your bundle. Some service providers voluntarily provide alerts to consumers when they reach their package limit, however some service providers do not so you should check this in order to avoid bill shock.

Early Termination Fees on your bill

Please note that details of the fees that a service provider will charge you if you switch to a provider when you are still in a contract will be outlined in the terms and conditions of your contract.

Compare service providers pricing

ComReg Compare is a tool which allows consumers to compare fixed line telephone charges across all providers. The site helps consumers to select the optimum phone package, based on their individual usage.

Disputed Private Branch Exchange (PBX) charges for Business Customers

Businesses may experience instances where their business telephone system (a Private Branch Exchange or PBX) is hacked and the business is faced with larger than normal bills for calls made by the parties hacking their system.

Regulation 23(2) of the Universal Service and Users’ Rights Regulations (S.I. 337 of 2011) gives ComReg powers in relation to fraud and misuse on telecommunications networks.  ComReg recently published an Information Notice for service providers in relation to this topic: ComReg 18/119.

The service provider of the affected business should report the matter directly to ComReg via email.

The business must formally report the matter to An Garda Síochána and provide the Garda PULSE number to their service provider.

Disputed data charges

Most service providers charge per megabyte or kilobyte of data accessed and where a consumer has not elected to go on a specific package, the charges can be very high.

Our role is to ensure that accurate pricing information is available to customers, and that service providers comply with their own pricing policy.

Most service providers have processes in place whereby they will attempt to notify consumers if their data downloads are likely to result in very high bills. Consumers should check this with their service providers. Where this is not done, we would advise the customer to lodge a complaint.

“Unlimited” broadband / data and Fair Usage Policies

A number of telephone and broadband packages are described as ‘unlimited’. In this context, the word ‘unlimited’ would normally be taken to mean that a consumer, having agreed to pay a set price, may make as many calls or spend as much time online as s/he wishes.  However, some service contracts qualify the meaning of ‘unlimited’ by stating that it is subject to an ‘acceptable’ or ‘fair’ level of use by the consumer. This is sometimes referred to as a “fair usage policy”.

We advise you that any contract which sets usage thresholds, or describes what constitutes ‘fair’ or ‘acceptable’ use, should be clear and unambiguous, particularly where the service is described as being ‘unlimited’. Usage thresholds or limits should be clearly set out, as should the manner in which they are updated or amended.

We expect each service provider to implement a clear, transparent and policy for dealing with customer usage above any set thresholds. The policy should set out the rules for contract termination, including penalties, the charges that shall apply for any use above the threshold/limit, and the policy regarding migration of the customer to other packages, if applicable.

We also advise you to carefully read the terms and conditions of your contracts and to be aware of the particular limits or thresholds that apply before purchasing.

Complaints about the advertisement of “unlimited” downloads while operating a fair usage policy should be raised with the Advertising Standards Authority for Ireland (ASAI) by the consumer.

Complaints about contractual terms and conditions setting out a fair usage policy without specific usage limits can be raised with ComReg by the consumer.

Tips for finding an unlimited mobile data plan for remote school or college

In many cases there is already a fixed broadband connection available to schoolchildren and college students, and this is good enough for their needs. Fixed plans can be compared on ComReg’s comparison tool at www.comreg.ie/compare

However, in some cases where a fixed connection is not available or a more temporary solution is needed, mobile data plans might be a good solution.

ComReg has put together some useful tips to getting the best unlimited mobile data plan for your needs.

1. Check with your current mobile provider

Explain your situation to your current mobile service provider and see what they can offer you in the circumstances, for example, if they can upgrade your current plan to unlimited temporarily or, if not, for a minimum term.  Be sure to get details of the offer in writing (email, etc.) so that you can consider it fully.

If you your  current service provider cannot offer a solution that suits your needs, in terms of data limits, speed, cost, etc. in light of the circumstances, then the following tips will be useful if you want to consider other service providers and offers.

2. Check the status of your contract and your handset

Here are some questions you should ask your service provider:

1. 1. Do you have a minimum term? What is it?
   2. Has your minimum term already expired?
   3. What are the fees for early termination?
   4. Do you own your handset?
   5. If you still owe money on your handset; how much is it to finish paying for it?
   6. If you own your handset, how can you get it unlocked? How long will it take? You will need to have an unlocked handset if you want to use a service from a different mobile service provider.

Click here for more information on handset unlocking

3. Look for a new mobile plan that suits your needs

ComReg’s compare tool at www.compare.ie/compare allows you to compare mobile plans as well as broadband, home phone and TV offers.  To compare mobile plans follow the steps below:-

a. Select the ‘Mobile Phone/plan only’ and ‘Show Me Everything’

b. You will be presented with a list of results (possibly over multiple pages) of mobile plans with the cheapest offer presented first.

c. Important considerations in this context are bill-pay or pre-pay (top-up); minimum term, monthly cost, data allowance, coverage and speed (assuming that sending texts and making voice calls are not very important to you). Click here for ComReg’s Outdoor Mobile Coverage Map

d. You can switch from “Cheapest per provider” to “All Results” to ensure that you can see all the plans available. You can compare these plans as presented in cost order, by clicking into them.

 

e. If you want to see all the mobile plans with the highest available,or unlimited data allowances included – switch the sort from “Average monthly cost (low to high)” to “Mobile Data (high to low)”.

On www.comreg.ie/compare  the data plans that are displayed as unlimited are those plans where there is no fair usage or acceptable usage limit.

As of 2 February 2021, page 1 of the ComReg Compare results pages (when this selection is made) shows:-

• • 13 mobile plans that are categorised as unlimited (these plans also include some voice minutes and texts).
  • 3 service providers offering these unlimited plans.
  • There are unlimited plans with a range of prices, some are pre-pay and some bill pay with varying contract terms.

4. Decide if you want to switch or get a new number

After looking at the offers and deciding what plan best suits your needs, think about whether you are switching your current number/subscription or getting a new/additional subscription.

If you are switching service providers, make sure you understand the implications if you are still within your contracted minimum term, including possible early termination fees.

Click here for more information on switching service providers

Whether you are getting an additional/new number/subscription with a different service provider or switching service providers you will need to have an unlocked handset to put your new sim into.

Click here for more information on handset unlocking