Slap a label on it! Making it easier for consumers to shop for telecommunications services

February 20, 2025

 

Intervention of the Competition Bureau

To

Telecom Notice of Consultation CRTC 2024-318, “Notice of hearing—Making it easier for consumers to shop for Internet services”

Table of contents

• Executive Summary
• Introduction
• Background: the Bureau’s efforts to promote competition in telecommunications
• Telecommunications markets in Canada
• This consultation is about helping consumers benefit from competition
• Switching isn’t always easy
• The Bureau’s recommendations: Making it easier for consumers to shop for telecommunications services
  • Recommendation #1: We support the adoption of a broadband consumer label to help consumers make informed decisions and enhance competition
  • Recommendation #2: Apply the label to wireless phone in addition to home Internet services
• Conclusion
• Footnotes

Executive Summary

In this consultation, the Canadian Radio-television and Telecommunications Commission (CRTC) is “considering whether it should require ISPs to display information in a standardized way for anyone who is shopping for a home Internet plan or who has already signed up for one.”^{Footnote 1} This submission provides the Competition Bureau’s (Bureau) analysis of the issue and makes recommendations to improve this important aspect of competition.

Choosing a service that fits your budget and your needs should not be difficult, but research consistently shows that for too many, it is.

The Bureau supports the CRTC’s efforts to standardize information about telecommunications services. Providing consumers with clear, concise information in a widely recognized ‘nutrition label’ format will lower barriers to switching, empowering consumers and improving competition.

Barriers to switching are barriers to competition. When companies worry about losing out to the competition, they may work harder to keep their customers—so even people who switch plans but stay with their current provider are taking advantage of the benefits of competition.

Minimizing the effort it takes to switch—or even just the perception that switching is a difficult thing to do—plays a critical role in empowering consumers to take advantage of the benefits of competition.

In our submission, we respond to issues raised in questions that are in our view most relevant to reinforcing the positive relationship between consumer choice and competition. As a result of our analysis, we have provided the following recommendations:

Recommendation #1: We support the adoption of a broadband consumer label to help consumers make informed decisions and enhance competition.

• Service providers should be required to provide information in a standardized form and manner
• Using the broadband consumer label format to provide standardized information is a good idea
• The broadband consumer label should include key information about price, fees, service characteristics and performance
• Canadians should have convenient access to the broadband labels at the point of sale
• The broadband consumer labels should be widely accessible

Recommendation #2: Apply the label to wireless phone and home Internet services.

• The CRTC should adopt the broadband consumer label requirement for home Internet services as well as wireless phone services
• Almost all Canadians rely on these services
• Consumers have similar issues with both types of service
• Applying the label to both services would maximize its benefit for Canadians

We hope that our submission will be helpful to the CRTC and look forward to supporting its ongoing efforts to promote competition in Canada’s telecommunications markets.^{Footnote 2}

Introduction

1. Making it easier to switch service providers and enabling informed consumer choice benefits consumers and increases competitive intensity in the marketplace.^{Footnote 3}
2. In this consultation, the CRTC is “considering whether it should require ISPs to display information in a standardized way for anyone who is shopping for a home Internet plan or who has already signed up for one.”^{Footnote 4} By minimizing the effort that it requires to compare services, these improvements will help to eliminate the barriers to switching that consumers face in the telecommunications market.
3. Barriers to switching are barriers to competition. When companies worry about losing out to the competition, they may work harder to keep their customers—so even people who switch plans but stay with their current provider are taking advantage of the benefits of competition.
4. This submission analyzes the issue and makes recommendations to improve this important aspect of competition.

Background: the Bureau’s efforts to promote competition in telecommunications

5. The Bureau’s role is to protect and promote competition for the benefit of Canadian consumers and businesses. As part of our mandate, the Bureau advocates for the adoption of laws and regulations that make the most of competitive markets.
6. Competition drives economic growth. It encourages businesses to innovate and become more productive. It benefits consumers because competition lowers prices, increases choice, and improves service quality.
7. The Bureau recognizes and strongly supports the CRTC’s ongoing efforts to improve competition in Canadian telecommunications markets.
8. The Bureau has worked to assist the CRTC on a wide range of competition issues in recent years. For example, we have participated in CRTC consultations on issues such as:
   • mobile wireless competition,^{Footnote 5}
   • home internet competition,^{Footnote 6}
   • wholesale costing methodologies,^{Footnote 7}
   • sector-specific codes of conduct,^{Footnote 8} and
   • providers’ pricing practices and sales practices.^{Footnote 9}
9. We also published the results of our Broadband Market Study in 2019^{Footnote 10} and made recommendations to the Broadcasting and Telecommunications Legislative Review Panel in 2020.^{Footnote 11} More recently, we opposed the merger between Rogers and Shaw to protect competition for the benefit of consumers.^{Footnote 12}
10. The Bureau welcomes this opportunity to help improve the quality and availability of information that telecommunications subscribers need to make informed decisions. By making information more relevant and accessible the CRTC can help consumers take advantage of the competition to get better, more innovative services at lower prices.^{Footnote 13}
11. To prepare our submission, the Bureau met with stakeholders, including other regulators, agencies, and subject matter experts. We conducted research and analysis using a variety of publicly available sources. Our comments are also informed by the Bureau’s Behavioural Insights Unit (BIU).^{Footnote 14} The BIU’s input focused on providing evidenced-based best practices for empowering consumers by minimizing the effort and cognitive burden required to switch telecommunications plans or providers.
12. Switching telecommunications plans or providers can take considerable time and effort, and switching costs impede the competitive process. Access to information that’s trustworthy, relevant, and easy for people to understand and act upon can help make it easier. It can also be useful in reducing the reality (and the perception) that switching is a hard process. Reducing barriers to switching can empower people, make their lives easier, and enable greater competition.

Telecommunications markets in Canada

13. Every day, people across the country rely on telecommunications services in their work and personal lives. In 2024, there were 36.7 million mobile phone subscribers in Canada^{Footnote 15} —roughly 95% of adults in the country have a cellphone.^{Footnote 16} At the end of 2023, 13.7 million Canadian households (93% of all homes) subscribed to Internet services, and the CRTC reports that it is on track to reach its target for universal service across the country by 2031.^{Footnote 17}
14. All of these subscriptions add up to a significant amount of economic activity. Together, wireless phone and internet services generated total revenues of about $49.5 billion CAD in 2023,^{Footnote 18} making up about 83% of the telecom industry’s overall revenue of $59.6 billion for the year.^{Footnote 19} The value of these services extends beyond the sector itself: research consistently shows that productivity in other sectors can improve by leveraging telecommunications services, for example.^{Footnote 20}
15. For wireless services markets, the largest three carriers account for a substantial majority of national revenues and subscribers. Bell, Rogers, and Telus collectively brought in 89.5% of revenues for the sector in 2023 (a slight increase from 2020),^{Footnote 21} and together they had a similarly high share of subscribers, at 86.9%.^{Footnote 22} For home internet markets, “incumbent telecom service providers” like Telus and Bell and “cable-based carriers” like Rogers, Videotron, Cogeco, and Eastlink together held 87.3% of revenues and 88.2% of subscribers in 2023.^{Footnote 23}
16. These markets are lucrative, and they’re also highly concentrated. In wireless markets, Bell, Rogers, and Telus compete amongst each other, but their market power continues to raise concerns in markets across the country.^{Footnote 24}
17. In recent years, regional players like Videotron, Freedom,^{Footnote 25} and Eastlink have entered wireless markets and expanded their businesses as well. In places like Thunder Bay and Saskatchewan, established regional players continue to maintain a strong local presence.^{Footnote 26} Today, while many Canadians can choose from between four wireless providers, others may have fewer options due to a variety of factors, including their living circumstances or service requirements.^{Footnote 27}
18. In home internet markets, our 2019 Broadband Market Study found that the majority of Canadians continued to obtain internet from one of Canada’s traditional telecom companies, and at the time people were turning to independent competitors in increasing numbers.^{Footnote 28} However, significant consolidation in recent years has raised questions about the future role of independent competitors. Additionally, Canadians in rural and remote areas continue to have fewer choices and face higher costs for service than people who live in urban areas.^{Footnote 29}

This consultation is about helping consumers benefit from competition

19. The Bureau is aware that many consumers continue to experience significant dissatisfaction with a lack of robust competition in the telecommunications marketplace. We regularly receive complaints from concerned members of the public urging us to take action on this issue, and we take these concerns seriously.
20. We aren’t the only ones who hear about these problems. The industry ombuds office (The Commissioner for Complaints for Telecom-television Services, or “CCTS”)^{Footnote 30} received a record number of complaints about their telecom and television services providers in 2024.^{Footnote 31} Concerningly, the CCTS observed a 261% increase in complaints about monthly service plan price increases in 2024,^{Footnote 32} and CCTS Commissioner Howard Maker has noted a “troubling increase” in problems customers have had with switching providers and service cancellation in particular.^{Footnote 33}
21. This all points to a problem: Canadians are either missing out on or being denied the benefits of competition in markets for essential services—and they’re not happy about it. Clearly, more work needs to be done to broaden Canadians’ access to the benefits of a competitive telecommunications market.^{Footnote 34}
22. Reducing barriers to switching is an important part of enabling consumers to choose plans and providers that meet their needs. The CRTC has already put a number of measures into place to make it easier for customers to take advantage of the competition by switching:
    • Number portability rules allow customers to keep their number when they switch.^{Footnote 35}
    • The Wireless Code places limitations on contract length and requires providers to sell devices “unlocked” by default.^{Footnote 36}
    • The Internet Code provides similar protections to customers in that market.^{Footnote 37}
23. The Bureau believes that the CRTC should build on these successes by continuing to reduce the effort it takes for consumers to switch.

Switching isn’t always easy

24. Breaking down barriers to switching plans and/or providers is key to making sure that consumers can benefit from competition in telecommunications markets. Minimizing the effort it takes to switch, or even just the perception that switching is a difficult thing to do, can play a critical role by empowering consumers to take advantage of the benefits of competition.
25. A 2024 survey conducted on behalf of the Canadian Telecoms Association found that people benefit from switching wireless plans or providers. According to that poll, 3 in 5 people who switched in the last year reported getting better pricing than they did with their old plan. It also found that 86% of people who changed their plan reported that they are getting a better deal overall, either better pricing or more service for the money, or both, than they were before.^{Footnote 38}
26. However, the same survey also indicates that only one in four Canadians has switched wireless plans in the last 12 months. This suggests that as many as three in four subscribers could be getting a better deal by switching from their existing plan to a newer one.^{Footnote 39} CRTC data also support this observation. According to the CRTC’s Communications Market Reports, just 1.2% of wireless phone or home Internet subscribers changed provider on average each month in 2023 (the number was the same for both sectors).^{Footnote 40}
27. Many consumers continue to face barriers to switching wireless phone and/or home Internet plans. Their difficulties are reflected in the issues consistently raised in complaints to the CCTS—wireless and internet issues accounted for 79% of all issues raised, with billing issues topping the list of complaints.^{Footnote 41}
28. Canadians are not just complaining in record numbers about problems with their existing plans. The CCTS also observed that consumers are reporting increased challenges associated with switching or cancelling services. For example, CCTS data show that:
    • Termination fee issues increased by 35% in 2024;
    • issues with being unable to cancel increased by 47% (after increasing 31% the year before); and
    • issues where customers could not transfer their service to another provider increased by 25% (after a previous increase of 23%).^{Footnote 42}
29. These numbers suggest that consumers would benefit from measures that make it more convenient to change plans and/or providers. In a recent media interview, CCTS Commissioner Maker called this trend a “head scratcher.” He also noted that “consumers are supposed to be able to switch simply, easily, no muss, no fuss, and it’s not happening.”^{Footnote 43}
30. The CRTC’s Market Reports also show that more than four out of ten (42.7%) of all wireless subscribers are on contracts that last at least a year.^{Footnote 44} Customers who have contracts can face especially high barriers to switching, such as termination fees or other penalties tied to the increasingly high cost of smartphones.^{Footnote 45}
31. The Bureau is also aware that service contracts have become increasingly common for home Internet services in recent years. CCTS data suggest that Internet contracts may have similar implications for switching as they do in wireless markets: customer issues with termination fees and being unable to cancel Internet services both rose by more than 50% in 2024.^{Footnote 46}
32. For many customers who are on-contract, the window of opportunity to shop around and consider switching service plan or provider can be limited to the time when the contract is set to expire. Recent public opinion research conducted on the CRTC’s behalf confirmed that most wireless and home Internet subscribers “do not tend to research or shop very often” and that those who do “tend to do so when their contracts are expiring and/or up for renewal.”^{Footnote 47} This is why it’s particularly important that customers can get easy access to relevant and trustworthy information when and where it matters the most.
33. The CCTS has indicated that it will continue to monitor these issues, since “one of the primary objectives of the CRTC’s consumer codes is for customers to be able to more easily switch providers in a dynamic marketplace.”^{Footnote 48} The Bureau agrees with this important objective. Switching should be as effortless and convenient as possible for consumers. Taking advantage of the competition should not impose a cognitive burden on people—the process should be convenient and easy to understand.

The Bureau’s recommendations: Making it easier for consumers to shop for telecommunications services

34. Our comments are focused on approaches that are meant to help customers take advantage of the benefits of competition in telecommunications markets. We believe that empowering consumers with better information about their options and minimizing the effort it takes to compare services has the potential to enhance market competition.
35. In this consultation, the CRTC is “considering whether it should require ISPs to display information in a standardized way for anyone who is shopping for a home Internet plan or who has already signed up for one.”^{Footnote 49} The Bureaus’ responses to the CRTC’s questions are below; our focus is on responding to the issues most relevant to competition and we therefore do not provide answers to every question asked by the CRTC.

Recommendation #1: We support the adoption of a broadband consumer label to help consumers make informed decisions and enhance competition

Service providers should be required to provide information in a standardized form and manner

36. The Bureau supports a requirement for telecommunications service providers to provide information in a standardized form and manner. Ensuring that consumers have convenient access to relevant, standardized information for their telecommunications services can empower people to make informed decisions and enhance competition in the marketplace.
37. This position is consistent with our previous advice to the CRTC. In 2018 we recommended that providers should be required to present customers with pre-sale quotes that are clear, simple, and standardized. That recommendation was based in part on the observation that “consumers are not always provided with sufficient information, or information that is explained in an adequately clear manner, to make informed purchase decisions.”^{Footnote 50}
38. Recent survey research conducted on behalf of the CRTC suggest that this is still the case. According to the CRTC’s Public Opinion Research, “Many participants said that the pre-sale information they came across was hard to place a value on” and that they “often described the information they get from providers to be biased in a marketing direction.”^{Footnote 51}
39. Indeed, the CRTC’s research also suggests there is a strong demand for standardized information to help consumers comparison shop for telecommunications services. More than 80% of participants felt that standardized information in a recognizable format— “something like a nutrition label but for home Internet services” —would be beneficial, and the number went up to nearly 9 out of 10 when provided with examples.^{Footnote 52}
40. The Bureau agrees that such a label could be beneficial for consumers and competition.

Using the broadband consumer label format to provide standardized information is a good idea

41. The Bureau supports the use of a standardized broadband consumer label to make comparison shopping easier for consumers. A standardized label should help:
    • simplify the aspects of service that are most important to customers,
    • facilitate apples-to-apples comparisons,
    • minimize the effort it takes to shop for telecommunications services, and
    • empower consumers to choose a service that meets their needs, based on what is most important to them.
42. The Bureau supported a similar approach during its participation in the CRTC’s 2018 consultation on the Internet Code.^{Footnote 53} Since that time, the United States Federal Communications Commission (FCC) has required providers to display a standardized “broadband consumer label” based on the nutrition label format that is already widely recognized and well understood among consumers.
43. The CRTC’s public opinion report observed that “perhaps it should not be surprising for this study to have found a fairly high level of appreciation for the nutrition label concept”, since “the most widespread pain point when it comes to pre-sale and post-sale information is the difficulty in clearly understanding everything any one offer or agreement represents and the ability to compare that with all other offers available”.^{Footnote 54} The report quantified participants’ appreciation as follows: “support for introducing the label concept into Canada is strong at 79% with virtually no opposition (4%).”^{Footnote 55}
44. The FCC label was developed through a thoughtful, inclusive consultation process that incorporated a wide range of feedback from the public, experts, industry and advisory groups, and it has undergone iterative improvement since it was first introduced.
45. The Bureau believes that the FCC’s model represents a robust and practical way to empower consumers to make informed decisions about the services that are best for them. It could be adopted by the CRTC with little modification, making it not just a good idea but an efficient one, too.

The broadband consumer label should include key information about price, fees, service characteristics and performance

46. In the Bureau’s view, the label should feature key information up-front, so consumers don’t have to search for the details they need to make important decisions. It should also incorporate reference to clear definitions and explanations, ideally presented on the same page to minimize navigation and reduce cognitive burden. This approach helps streamline the user experience by minimizing effort while ensuring that the information is framed in a way that is easily understandable and accessible.^{Footnote 56}
47. In the Bureau’s view, the FCC’s approach provides a helpful model that could, with modifications that appropriately reflect the Canadian legal context, guide the CRTC in the development of its own broadband consumer label. As the FCC explains, “Consumer access to clear, easy-to-understand, and accurate information is central to a well-functioning marketplace that encourages competition, innovation, low prices, and high-quality services.”^{Footnote 57}
48. With regard to content, the FCC’s broadband consumer label contains “critical information about the provider’s service offerings, including information about pricing, introductory rates, data allowances, performance metrics” and reference to network management and privacy policies.^{Footnote 58}
49. Specifically, the FCC’s broadband labels include the following information:

Pricing information

55. The Bureau believes that this requirement should be modified for the Canadian context. Specifically, the Competition Act contains civil and criminal provisions that expressly prohibit drip pricing, as follows:
    • For greater certainty, the making of a representation of a price that is not attainable due to fixed obligatory charges or fees constitutes a false or misleading representation, unless the obligatory charges or fees represent only an amount imposed on a purchaser of the product referred to in subsection (1) by or under an Act of Parliament or the legislature of a province.^{Footnote 64}
56. Taking a “made for Canada” approach to the label means adopting a different way for the label to represent prices than the method chosen by the FCC. In order to ensure that its requirements are in harmony with the relevant statutes, and to prevent the use of drip pricing in particular, the Bureau encourages the CRTC to require providers to display an “all-in” monthly service price in the label. The “all-in” price would have to be inclusive of any fixed obligatory charges or fees (excluding government fees as described above).
57. We note that a significant purpose of the label is to minimize the effort it takes to compare services so that consumers are empowered to make informed decisions. Ensuring that the method used to display prices is uniform across the marketplace is therefore the crucial element of this task.
58. Potential limits to service. The FCC also requires that limits to service, such as data caps and the consequences for going over them, must be clearly disclosed as well. While the Bureau recognizes the importance of this type of disclosure, we note that it and other information contained in the label cannot be used or relied upon to restrict, contradict, or negate any marketing messages, or otherwise cure misleading advertising or deceptive marketing practices.

Performance information

59. Speed and latency metrics. Providers must display typical download and upload speeds as well as latency metrics in the labels. The FCC included these measures because “speed has historically been one of the most important agreed-upon metrics for Internet performance,” and because “latency is important to any application involving users interacting with each other, a device, or an application.”^{Footnote 65}
60. The Bureau does not take a position at this time with regard to the preferred method for measuring speed or latency. We note, however, that consistency is crucial for making comparisons. Whatever method the CRTC ultimately adopts for measuring performance must be applied uniformly to be helpful for consumers and competition.

Terms and conditions

61. Providers’ policies have important implications for consumers, but they can be long, complicated, and hard to boil down into short form without losing crucial information. For terms and conditions that don’t lend themselves to summary but are nevertheless important for consumers, providers are required to include link(s) in the label. These include:
    • network management policies;
    • privacy policies;
    • availability of low-income programs, and corresponding eligibility criteria;
    • additional educational materials (e.g. customer support, CRTC and CCTS consumer information such as glossary and FAQ’s)
62. Finally, although providers are permitted to include links to information about available promotions or discounts,^{Footnote 66} we observe that the FCC otherwise restricts what information may be displayed as part of the label. The reason for this is because it is important for consumers to see the label as a trustworthy, impartial source of information that serves their interests, rather than part of providers’ marketing efforts.
63. The Bureau agrees that it is crucial for the label to be a credible source of information that unequivocally serves consumers’ interests. To that end, we note that the Competition Act prohibits false or misleading advertising. Should the CRTC adopt a broadband consumer label as a result of this proceeding, it will be necessary for providers to ensure that all advertising is entirely consistent with the information on the label in order to be compliant with the requirements of the Competition Act.
64. As the FCC observes, providing labels that contain the information above “empowers consumers to choose services that best meet their needs and match their budgets and ensures that they are not surprised by unexpected charges or service quality that falls short of their expectations.”^{Footnote 67}

Canadians should have convenient access to the broadband labels at the point of sale

65. For the labels to be useful, they need to be available where and when consumers are shopping for service.
66. The FCC requires providers to display the labels “at the point of sale.”^{Footnote 68} They define this in broad terms as “a provider’s website and any alternate sales channels through which the provider’s broadband internet access service is sold, including a provider-owned retail location, third-party retail location, and over the phone.”^{Footnote 69}
67. The FCC further clarifies that providers must display a label “for each stand-alone broadband Internet access service they currently offer for purchase.”^{Footnote 70} Labels located on websites must be displayed “in close proximity to the associated advertised service plan” as well, and cannot be presented in the format of an icon or link that directs shoppers to a separate page.^{Footnote 71}
68. These requirements are intended to ensure that the labels are conveniently accessible from “the time a consumer begins investigating and comparing broadband service offerings available to them at their location.”^{Footnote 72}
69. As the FCC puts it: “... we adopt requirements for the label’s format and display location to ensure consumers can make side-by-side comparisons of various service offerings from an individual provider or from alternative providers—something essential for making informed decisions.”^{Footnote 73}

The broadband consumer labels should be widely accessible

70. Maximizing the labels’ potential benefit for consumers means that they need to be formatted in a way that makes them informative and easy to understand. Ensuring that people can quickly grasp key information and that they encounter minimal friction in their decision-making process is crucial to empowering consumers.
71. The FCC designed its labels “so that they resemble the well-known food nutrition label” for these reasons.^{Footnote 74} It observes that food nutrition labels have already demonstrated several of the core best-practices needed to be effective, and the lessons they provide can be incorporated as follows:
    • adopting expert-endorsed recommendations on typeface, font size, and white space;
    • using uniform formats to best enable consumers to compare services and products;
    • limiting providers’ discretion to customize labels, since “customization undermines the central function of the label—to facilitate comparison shopping between providers and services.”^{Footnote 75}
72. The label format presents information in an easily accessible and understandable way, so that consumers will not have to search for key details (e.g., buried at the bottom of a page), or expend excessive effort trying to interpret complex information. Placing the key details front and centre helps shoppers to avoid unnecessary navigation, freeing up time. This will make the process convenient for consumers and increase their chances of engaging with and benefitting from the labels.^{Footnote 76}
73. The FCC has adopted further measures to ensure that the labels are flexible enough to meet the diverse needs of telecommunications consumers. The CRTC could take the following steps to adapt these measures to ensure that they fit the Canadian context:
    • require labels to be available in any language in which a provider normally markets its services;
    • require that labels be available for description over the phone, accommodating people who are blind; and
    • permit providers to use customer location information, where required for determining service availability, to improve the relevance of the labels for specific customers.^{Footnote 77}
74. The FCC also makes the labels accessible by requiring them to be available in a machine-readable format and with unique identifiers. This measure is meant to “enable third parties to easily analyze information and help consumers with their purchase decisions by requiring providers to make the label content available in a machine-readable format.”^{Footnote 78}
75. The FCC is explicit in its intentions: “Machine readability also promotes both competition as well as transparency and accountability [...] the generation of tools like these helps promote “digital equity” for groups lacking the necessary expertise”.^{Footnote 79}
76. Making the labels accessible in this way could also help to improve understanding of market dynamics, not just for consumers directly but also among groups who monitor or play other roles in the sector, such as ISED, the CRTC, the CCTS, Statistics Canada, and independent researchers. The FCC notes that its label requirements will assist in monitoring compliance by ensuring that a record of service plans is preserved; in the Canadian context this could also assist the CCTS in adjudicating disputes.
77. Additionally, the machine readability requirement makes data more easily available to researchers who can help to monitor the industry’s performance for the benefit of Canadians.
78. The FCC provides guidance on how to implement machine readability, including detailed instructions and templates, so that “these benefits can be achieved at a low cost to providers.”^{Footnote 80}
79. The Bureau agrees that the labels should be as widely accessible as possible and believes that the FCC’s model is a good starting point that the CRTC could adapt for use in Canada.

Recommendation #2: Apply the label to wireless phone in addition to home Internet services

The CRTC should consider adopting the broadband consumer label requirement for wireless phone services as well

80. At present, the CRTC is only seeking to require certain providers of home Internet services to adopt the broadband consumer label—that is what the recent amendments to the Telecommunications Act require it to do.^{Footnote 81} However, it is not prevented from applying such a rule to providers of wireless phone services, and there are a number of reasons why doing so could be a good idea at this time.

Almost all Canadians rely on these services

81. As the Bureau has already noted, the vast majority of Canadians rely upon telecommunications services—both home Internet and wireless phone services—in their daily lives. In addition to the nearly 14 million home Internet subscriptions in Canada, there are more than 36.7 million wireless phone subscriptions across the country, and roughly 90% of these plans include broadband service in addition to voice and text.^{Footnote 82} Requiring providers to apply the broadband consumer label to both services therefore has the potential to significantly extend the benefit of the better information to millions of Canadians.

Applying the label to both services would maximize its benefit for Canadians

82. Consumer issues with telecommunications services are not limited to home Internet markets. As the CCTS noted for 2024, “wireless issues remain the most-raised issue, accounting for 52% of all issues raised. Wireless issues increased by 27% this year.”^{Footnote 83} The CCTS data suggest that the nature of complaints is broadly similar between the two services as well, with billing issues such as incorrect charges and increases to monthly price plans topping the list in both categories.^{Footnote 84}
83. The CRTC’s public opinion research also found that only 56% of participants were at least somewhat satisfied with their ability to compare pre-sale information provided by different service providers, and that 19% were dissatisfied.^{Footnote 85} These findings suggest that applying the labels to wireless phone services could be helpful for a significant number of Canadians.
84. Adopting the label for wireless services could therefore have a similar helpful effect as what’s expected for home Internet services. Indeed, the 2023 Policy Direction urges the CRTC to harmonize the provisions of its consumer codes of conduct where doing so would be advantageous to consumers.^{Footnote 86} Considering the substantial benefits that the broadband consumer label could deliver, the Bureau believes that the CRTC should take this opportunity to consider extending its application to wireless services as well.
85. The Bureau also notes that the country’s largest wireless carriers, which together accounted for 87% of wireless phone subscribers in Canada at the end of 2023,^{Footnote 87} each also offers home Internet services. This is also true of most other wireless providers operating in Canada (or their affiliates). For this reason, the marginal cost of extending the label’s application to wireless service for an integrated provider would be less than for stand-alone wireless providers.
86. Indeed, extending the label to cover wireless phone services may create additional benefits as overall familiarity with the label format is extended to improve consumer literacy more broadly throughout the telecommunications marketplace.

Conclusion

87. The Bureau supports the CRTC’s ongoing efforts to improve competition in Canadian telecommunications markets. Competition plays a central role in making sure that consumers and businesses across the country have a choice of affordable telecommunication services that meet their needs.
88. In recent years, the CRTC has taken several important steps to empower consumers in their relationships with their telecommunications service providers. Ensuring that phone numbers are portable, placing limits on contract length, and unlocking devices have brought consumer benefits and have helped foster competition in the marketplace.
89. The Bureau is pleased that the CRTC continues to build on these achievements. A broadband nutrition label can put consumers in the driver’s seat of the switching process and improve competition in telecommunication markets. With clear, standardized information to compare their options, consumers can take advantage of competition more easily, and companies will compete harder to keep them.
90. Thank you for your consideration, and we look forward to supporting the CRTC’s future efforts.