Empello has provided a detailed response to the UK regulator’s current consultation on making Double Opt-in compulsory for all Subscription services billed by Direct Carrier Billing (DCB) in the UK.
VAS or DCB services in the UK already use a two step payment confirmation process, but the PSA definition of formal Double Opt-in requires one of the following:
- a secure PIN loop
- a password system
- an SMS sent by the consumer
Of these options, many providers in the industry would see PIN as the least intrusive, but nevertheless believe the impact on business would be very significant.
The issues around subscriptions are complex and multi-faceted. Empello feels they cannot be addressed by legislating on one aspect alone of the user experience. Indeed, a unilateral tightening of this regulation may exacerbate some of the challenges currently faced by the industry.
Aside from the very concentrated global OTT players, the rest of the VAS sector is currently facing a fight for survival. Due to commercial and operational factors, the pay-out rates from Carrier Billing are significantly lower than those of Credit Cards and other payment mechanisms.
To counter this, what Carrier Billing can offer as a USP, is a lower friction payment experience. Over recent months there have been noticeable improvements to the quality of both the services as well as the marketing of VAS. This has been driven by considerable investment from serious providers, to harness the potential of Carrier Billing by delivering great services.
In its consultation response, Empello sets out evidence from other countries around the world, as well as other DCB sectors in the UK, where the imposition of such a high-friction payment experience has not solved consumer problems. In most cases, such an approach has made it more difficult for good providers to market and deliver their services, whilst also having the effect of reinforcing aggressive marketing and other sub-optimal tactics/products.
For the full Empello response to the consultation please click the link below: