aimm has been successfully representing members’ interests to key regulators since 1995. aimm is at the forefront of regulatory change, ensuring that Members’ collaborative views on regulation are heard. aimm analyses every consultation released to check whether Member’s businesses could be affected and will then organise and deliver a response to the regulator, after member’s views and responses are collaborated. When a new consultation is released aimm will reach out to its members to call for feedback before delivering a considered and measured response.
03/07/2020 aimm report for PSA Code 15 DiscussionThis report has been prepared by Fladgate LLP on behalf of the Association for Interactive Media and Micropayments (aimm) in connection with aimm’s response to a ‘Discussion Paper’ published by the Phone paid Services Authority (PSA) on 27 February 2020 (Discussion Paper). The purpose of this report is to inform PSA’s approach to its revised Code of Practice and, more fundamentally, help it assess whether the structure of PRS regulation in the UK needs to be revisited. To that extent, our review of the countries covered below has demonstrated that there are a number of differing approaches to the fundamental question of how to ensure regulation protects consumers and also contributes to (rather than hindering) a vibrant and dynamic PRS industry.Date OpenedFebruary 2020Deadline2 July 2020
03/07/2020 PSA Code 15 Best Practice Discussion DocumentThe PSA are undertaking a review of their current Code of Practice (Code 14)1 to ensure their regulation remains fit for purpose and relevant. The PSA want to make sure the Code provides the right incentives for businesses to operate responsibly and the right deterrents for those firms that seek to enter the market to exploit consumers or who do not put the right consumer protections in place. Through this review, they will carry out a strategic assessment of their current regulatory approach, taking account of market developments and changing consumer behaviours, expectations and needs. The purpose of this document is to seek early input from stakeholders to inform the development of proposals on which the PSA will consult in Autumn 2020. They want to ensure that any proposals they develop are based on a sound understanding and accurate assessment of all available information and evidence and informed by stakeholder input. aimm have met and consulted with their members on numerous occasions since February to get a clear view on this new proposal to the Code. aimm have submitted their response to the PSA based on this before the deadline fo the 2nd July and have also worked with Fladgate Solicitors to prepare a detailed report, with the purpose of this report to inform PSA’s approach to its revised Code of Practice and, more fundamentally, help it assess whether the structure of PRS regulation in the UK needs to be revisited. This will be uploaded separately.Date OpenedFebruary 2020DeadlineJuly 2020
04/02/2020 PSA consultation on Budget and Business Plan 2020-2021 – aimm response
The business plan sets out the work we are planning in 2020/21, including the development of a new Code of Practice.PSA are proposing a real terms flat budget, meaning will have reduced the budget by 21% over five years. To support this, PSA are proposing an adjusted levy of 0.36% on outpayments made by networks. aimm has worked with members to gather feedback from across industry and then submitted a considered response.Date Opened16th December 2019Deadline23rd January 2020
04/02/2020 PSA Consultation on revised guidance on Consent to Charge – aimm response
The Phone-paid Services Authority (PSA) is consulting on new General Guidance for Consent to Charge mechanics within the phone-paid services industry.This guidance is intended to ensure that standards of payment/consent platform security remain high throughout the phone-paid services market. It will help networks and phone-paid service providers by clarifying the PSA’s expectations in this area. The guidance covers three key areas:
Date Opened14th August 2019DeadlineOctober 2019
- why informed and robust consent is important
- expectations around informed consent and consumer purchase journeys
- expectations around robust payment and verification platforms.
04/02/2020 PSA 2nd Consultation on changes to regulatory framework of ICSS – Annex B
The proposals are intended to improve the information about these services that is given to consumers, both in search results and on service websites, to make it clearer that they are third parties and that calls via an ICSS may be more expensive than calling the desired number directly.These proposals follow changes in January 2019 to extend the scope of Ofcom’s Premium Rate Service Condition to include all ICSS within the definition of controlled premium rate services. This extended PSA regulation to all ICSS irrespective of the number range they are operating on. Initial deadline for consultation responses was June 2019, but this was extended to October 2019 due to additional updates and changes added by PSA. aimm worked with members to gather feedback and then submitted a considered view to this consultation. This is the annex that was created due to the additions presented by the PSA.Date Opened29th April 2019DeadlineOctober 2019