On 25 October 2011, the Commission for Communications Regulation (“ComReg”) notified Vodafone of findings that it had not complied with its licence conditions and related statutory obligations in relation to its implementation of electronic billing (e-billing). This could even lead to losing its license in Ireland.
Background
The mobile operator recently began informing customers that they would in future be receiving their bills online in stead of by mail. The move was expected to affect just under 200,000 of the company’s 2.4 million customers. However ComReg’s intervention will end the practice for these 200.000 customers.
From a malicious OPT-OUT to proactively OPT-IN
Vodafone was forced to propose a comprehensive and proactive programme of customer communications, covering all of the customers affected, so as to verify customer preferences and agreement regarding the type of billing that they wish to receive, in accordance with the principles of consumer choice and consent. Wow!
Based on this programma, COMREG has decided that, as the above approach addresses the Commission’s concerns and takes full account of the preferences of consumers, it will not take further enforcement action at this time.


