Communications Ombudsman & BT · Working Tool

Raising the Bar

Communications Ombudsman Part of Trust Alliance Group
Consumers helped earlier
cases resolved before reaching CO
0 in 50
Today: 0 · waiting to be raised
Opportunity for providers to act — realisation depends on provider engagement
Quicker resolution
days saved at CO · deadlock to decision
0 days
Today at CO: ~56 days · waiting to be raised
Deadlock Claim resolved
CSAT AfA trial-evidenced
Below par Industry-leading
Less effort for the consumer
manual actions removed from the journey
0 removed
Today: consumer drives the handover · waiting to be raised
Raise
complaint
Wait for
deadlock
Wait for
letter
Find CO
website
Build the
case at CO
Engaged
with CO
CX score AfA trial-evidenced
High effort Industry-leading
The Outcome Remedy implementation
1–12%
overdue remedies today · waiting to be raised
Precise asks paired with realistic timeframes by remedy type — 99%+ on time, every time
The levers
Click to toggle. Each chip shows what it adds to the Bar above.
Principles

Four principles to raise the bar.

Four delivery propositions. No new legislation required. Each maps 1:1 to a section of evidence underneath. Status reflects real-world delivery maturity, not lever toggle state.

Evidence

What sits underneath each principle

Four sections, one per principle. Numbers are a mix of live operational data, trial-evidenced findings (from the energy-sector AfA trial), operational targets, and modelled ranges. Caveats named, not hidden.

Evidence base & why it transfers. The trial-evidenced figures come from the energy-sector AfA trial (British Gas cohort) and are shown transparently as such — they are not communications data. What transfers is the consumer behaviour and the design principles: simplified digital access, QR-as-consent, and a provider-branded signpost change how people engage with redress regardless of sector. The CO & BT model applies those principles to communications consumers; sector-specific figures are to be confirmed with BT.
Position holder: Communications Ombudsman · Levers on Overview: Stage 02 PITOR (CO → Provider) & Stage 03 Data Sharing (Provider → CO) · Both flows depend on a sector framework

The principle. Mutual Data Sharing is the principle that the sector works together to share data — both ways — for mutual good. CO and providers exchange structured information at the deadlock interface: CO shares pre-deadlock intelligence with providers (PITOR); providers share case data with CO at deadlock (the portal upload).

No new legislation is required. What is needed is industry collaboration to design and adopt the framework within existing data protection and regulatory structures. Two-way sharing works only when the sector designs it as a shared framework — both flows are designed to operate together.

Consumer evidence Consumers do not object — in survey or in practice
Consumer opt-out behaviour
0.52%
Only 8 of 1,533 consumers in the AfA trial chose to withhold their data from CO during the 14-day opt-out window.
AfA Trial Report § 6.1 · British Gas only
Consumer attitudes
69%
feel comfortable with businesses sharing their details with an ADR body. A further 68% expect it to happen. Active discomfort is low: 13% wouldn't expect it, 15% uncomfortable.
Perceptions of an Ombudsman survey, Feb 2026 · n=1,000 UK, nationally representative

Flow A — PITOR (CO → Provider). CO shares aggregated insights drawn from past casework with providers before their next case escalates to deadlock — patterns, similar-case learning, likely root causes. The provider uses that intelligence to resolve cases at source. The consumer never needs to engage with CO.

Consent basis. Aggregated and anonymised insights from CO casework, shared with providers on legitimate interest grounds. Individual case-level data is not transferred back to the originating provider through PITOR. Consumer consent boundaries from the original case scope are respected throughout.

Mechanics:
CO → Provider Aggregated / anonymised Pre-deadlock Legitimate interest basis

PITOR volume in 2025. CO live operational data, all sectors. Of 190,217 cases created in 2025, 35,841 (18.84%) entered PITOR — close to the “1 in 5” opportunity framing used throughout the tool.

18.84% of all 2025 cases entered PITOR — the headline opportunity
“Up to” ceiling, not forecast Realisation depends on provider engagement

Flow B — AfA v2 (Provider → CO portal). At deadlock, the provider uploads structured case data to a secure staging portal that CO has built and operates. The consumer's QR scan releases the case into CO's active workflow. v1 (direct transfer) was redesigned to v2 (passive staging repository) to address the GDPR concern providers raised — that outbound CO contact based on provider-shared data could create a direct marketing risk.

v1 Direct transfer Not used
Provider → CO direct. Consumer data lands at CO before consumer acts.
v2 Locked staging repository Used in this tool
Provider → staging repository (built and held by CO). CO has technical access but does not proactively use or contact based on this data. The consumer's QR scan activates a case. One narrow exception: case-existence check to avoid duplication if the consumer reaches CO via a non-QR route.
v2 conditions:
Providers retain lawful basis Providers handle privacy notice Providers handle transparency QR-as-consent: letter wording makes it explicit
What this means for the plan

Mutual Data Sharing is the gate because both flows above rest on the same sector framework. They are designed to operate together as one collaborative framework. Consumer evidence (0.52% opt-out behaviour, 69% comfortable, 68% expecting it) shows people don't object to the principle of structured sharing with an ADR body. Flow A (PITOR) operates on legitimate interest grounds with aggregated insights; Flow B (AfA v2) operates on QR-as-consent with the consumer activating their own case.

Source: Access for All Trial Report (10 March 2026) · British Gas only, 20 Oct – 22 Dec 2025 · Cohort 1: 1,533 cases · CX sample n=33 (indicative)
BAU
1Deadlock letter (generic signposting)
2Consumer searches for CO
3Reaches CO website
4Builds case from scratch
Case raised
~14 days
AfA v2
1Deadlock letter with QR code
2Consumer scans QR (= consent)
Case pre-populated & landed
~48 hrs

Three touches removed from the consumer's path. The QR scan replaces the "search → reach → build" sequence with a single deliberate action that also serves as consent.

Trial evidence Three independent measures point the same way — the QR letter is the active ingredient
Cohort 3 — reminder only, no QR
2.6%
engaged within 10 days. The negative control isolates the QR-letter design as the active ingredient.
AfA Trial Report § 6.2 · Cohort 3
BAU baseline
~40%
engaged within 10 days — today's letter-only journey.
AfA Trial Report § 6.2 · BAU control
AfA v2 (signposted QR)
75%
engaged within 10 days. Median engagement ~48 hours from receipt of the QR letter.
AfA Trial Report § 6.2 · AfA cohort
Show the full response-timing chart
Response timing — cumulative % of consumers escalating, by days from signposting letter
80% 60% 40% 20% 0% End of 14-day opt-out 75% 0–5 days 6–10 days 11–20 days 21–30 days 31–50 days 50–100 days 100+ days BAU (Cohort 4) AfA Trial (Cohort 1)
Recreation of the AfA report Section 6.2 chart. The AfA spike at 11–20 days lands exactly when BAU response is already tapering.
Effort score
70.6 84.9
+14.3 pts
Report § 6.3
Sought extra info
15%
assurance was high
Report § 6.4
Prior CO awareness
31%
low — the access barrier
Report § 6.4

Only 31% of consumers had prior awareness of CO — the access barrier is real. With the QR letter, only 15% sought further information; the journey was clear enough on its own.

CSAT
80.6% 96.5%
+15.9 pts
Report § 6.3
Comms satisfaction
90.6% 98.3%
+7.7 pts
Report § 6.3
Opt-out rate
0.52%
8 of 1,533
Report § 6.1

Because the letter stays on provider letterhead, the CSAT uplift reflects on the provider who initiated the journey — not just CO. The brand value of a well-handled deadlock sits with both parties.

On registering the dispute
“Investigation initiated by British Gas and they sent me a link to register my dispute.”
“Initiated by my energy provider.”
“Simple online form to submit.”
“Quick and easy to do online.”
On uploading evidence
“The system was able to access my mobile phone files.”
“Easy to do.”
On CO case handlers
“I spoke to a very well informed lady Louise who explained everything and made the process very easy.”
“My case handler got in touch with me really quickly and explained the process well.”
“Case handler was empathetic and understanding, took time to listen and note the issue, clearly advised on next steps.”
Several respondents explicitly noted that they would not have pursued their case without the simplified journey. — AfA Trial Report, Appendix 1
What this means for the plan

The Stage 04 Consumer Access lever makes the process better (CX metrics improved across CSAT, Effort, and Comms-sat) and removes steps (engagement compresses from a 14-day BAU median to ~48 hours). The Cohort 3 comparator (no QR, 2.6% conversion) shows the QR-letter design as the active ingredient, separating its effect from a simple reminder.

CX sample n=33 indicative Single provider (British Gas) Needs multi-provider validation at scale
Source: CO operational programme · Not an AfA trial finding · Lever on Overview: Stage 05 Investigation Period · Status: In progress
Today (BAU)
42 days
Target
28 days
−14 days saved
Delivered through:
Case prep Provider-facing teams Taxonomy-led classification Decision-quality QA
What this means for the plan

The Investigation Period lever makes the process better by compressing time-to-resolution by 14 days. Delivered independently of provider engagement through case prep, taxonomy work, provider-facing teams and decision-quality QA. The lever is an active CO programme.

Not AfA-evidenced — CO programme commitment
Source: CO casework analysis · Framework in build with regulator input · Lever on Overview: Stage 06 Remedies framework · Numbers indicative
Today
1–12% overdue
With framework
<1%
Why the range is wide:
Same-day apology: near-zero overdue Engineer install: depends on field teams One-size-fits-all SLAs don't fit
What this means for the plan

The Remedies framework makes the process better by replacing single-SLA enforcement with remedy-type precision — matching realistic timeframes to the actual remedy. The 1–12% range is a placeholder for discussion; the <1% target is a Stage 06 commitment in build with the regulator. The lever sits later in the journey and does not depend on Data Sharing, so can be delivered independently.

Placeholder for discussion Numbers to be confirmed pre-publication
Reference · Mobile

Communications Complaints Taxonomy

A true three-tier structure: broad categories, organised by the consumer's own voice, resolving to specific complaint details. Each detail carries its own regulatory anchor, remedy guidance and evidence prompts. This is the shared language CO and BT can investigate and report against.

Tier 1 · Category
8
Broad complaint areas. Customer Service is secondary — recorded alongside a primary substantive complaint.
Tier 2 · Sub-type
48
The consumer's own voice — how the issue is described in plain terms, before investigation.
Tier 3 · Detail
174
The specific resolved complaint, each mapped to impact, regulatory anchor, remedy and evidence.

Beyond the consumer-facing tiers, an investigator tags every detail with three controlled fields. These picklists are common across the whole taxonomy, so they sit here once rather than repeating on every row.

How the taxonomy drives the model

This is not a standalone reference. The same structure underpins three of the four principles in the plan — it is the classification layer that makes faster, fairer, more consistent resolution possible.

Principle 02
Cleaner consumer access
The consumer-voice sub-types are how a case is captured in plain language at the point of signposting — before any investigation. The taxonomy is the bridge between what the consumer says and how CO classifies it.
Go to Principles →
Principle 03
CO investigating quicker
Tighter classification routes each case to the right specialist first time, removing triage and reassignment. This is one of the four mechanisms behind the 42 → 28 day investigation saving.
Go to Principles →
Principle 04
Remedy-specific SLAs
Each detail carries its own remedy guidance, so SLAs can be matched to the actual remedy rather than a single blanket target. The taxonomy is where that remedy precision lives.
Go to Principles →