Mobile Number Portability in Ghana First Year Report National Communications Authority July 18, 2012 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 Key Points ? ? ? ? ? ? ? ? ? Mobile Number Portability (MNP), a system which allows mobile subscribers to change from one network to another without changing any part of their mobile number, was launched in Ghana on July 7, 2011. In the first year of MNP operation, 370,107 mobile numbers have been successfully ported by customers in Ghana. This represents 1. % of the total active mobile numbers in Ghana. Each of the mobile networks in Ghana have gained and lost customers through MNP. The overwhelming majority of customers who have ported have remained on the networks to which they ported, implying satisfaction with the process and the choice they made. The success rate of porting requests submitted in the first year of operation was 75%, including the early days of operation when the process was still unfamiliar. Average porting speeds in the 7 – 8 minute range have now been achieved.
The central MNP system is working well but some mobile operators still experience operational and technical problems that remain to be resolved. We are seeing too many instances of mobile network agents in the field porting customers’ numbers while the customer is being told they are just being given a new SIM. Background Between 1992 and 2008, six companies had been licensed to provide mobile service in Ghana. From approximately 2005 onward, growth in the total number of active mobile numbers here demonstrated that the market had become competitive and that Ghanaians had come to view mobile telephony as a necessity rather than a luxury.
However, it also became clear that a significant segment of the customer base was reluctant to take advantage of the choices available because their phone number would change when they open an account at another service provider. The expense and inconvenience of informing all their contacts of their new number and changing their stationery, business cards, and advertising messages outweighed their desire to change networks. Many customers opened accounts at two or more networks, which may have alleviated some of the difficulties they encountered at their original network but introduced 1
Mobile Number Portability in Ghana – First Year Report – July 18, 2012 complexities such as carrying multiple phones, swapping SIMs, and having multiple numbers. The first country to introduce Mobile Number Portability was Singapore in 1997. Many other countries have followed since, with implementations varying in major and minor detail. As one would expect, an examination of their results provided useful guidance in determining which decisions would work well for the consumer and which would not.
In Ghana, the mobile licenses issued since 2004 and the Electronics Communications Act 2008 anticipated the introduction of MNP as they contained general language requiring mobile networks to comply if and when it was introduced. By late 2009, as the Authority moved toward a greater consumer orientation and with various competitive market factors such as the number of operators and interconnection function and pricing well established, it became obvious that MNP was the necessary next step.
Consultants were engaged and the first stakeholder workshop took place in February, 2010. NCA understood that all the mobile operators had to be involved in every step of the process. The MNP Steering Group and its specialist subgroups was formed in April, 2010. To date, these entities have held over 100 meetings in preparation for, and management of MNP in Ghana. In May 2010, the first version of the Authority’s MNP Policy was released, to act as a guide for the Steering Group’s detail work.
The policy captured the key points that would ensure MNP success and support the key principles that porting should be fast, inexpensive, and simple for the customer: ? ? ? ? There would be a central system to coordinate porting. This system would pass the porting requests between networks and would also maintain a list of all the ported numbers and the network at which they are currently located. All networks would keep a copy of that list of ported numbers and would refer to it so they would know to which other network they should send calls and text messages.
Customers who wish to change networks and keep their phone number only need to visit the network they wish to join (known as the “recipient”) and do not have to contact the network they wish to leave (the “donor”). The donor may not contact the customer during the porting process, and is permitted to reject the porting request for a few limited reasons, such as the number not being active on their network, or the customer being with them for less than 30 days. Unlike some other markets, debt was not permitted as a reason for a donor to “block” a porting request, and 2
Mobile Number Portability in Ghana – First Year Report – July 18, 2012 ? ? ? ? notably, a year later, we have yet to see even one complaint about a customer using porting to avoid paying their debts. Porting should happen quickly, in 24 hours or less after the customer’s request If the customer wishes, he may port again to another network or back to his original network after 30 days. The cost of each port must be sufficiently low that each network can afford to cover it for any customer wishing to join them, not just for the heavy users who might come.
Any customer who ports his number must be permitted to retrieve any balance in their mobile banking account at the donor network, without charge. In July 2010, the Steering Group had finalized and sent out the Request for Proposals for the central MNP service provider. Nine companies submitted proposals, and in October 2010, after a thorough evaluation process, the Steering Group unanimously selected Porting Access Ghana Limited (“PXS”), a joint venture of Porting Access b. v. of the Netherlands and CIS Ghana Limited, to install and provide MNP service in Ghana.
By February 2011, PXS had commissioned the central system, and between March and June 2011, all mobile operators tested their systems with PXS and between each other. MNP Regulations were submitted to Parliament in June 2011; the system was ready for operation as of July 1; the regulations came into force on July 6, and on July 7, 2011, Mobile Number Portability was launched for consumers in Ghana. This 17 month period is one of the world’s shortest spans from decision to MNP launch. Statistics At the end of the first year of MNP in Ghana, July 6, 2012, 370,107 mobile numbers had ported successfully.
This represents approximately 1. 6% of the total active mobile numbers in the market, a figure reasonably comparable to markets in which MNP is considered successful. The Authority did not have any particular MNP target in mind, as each market is different and there were few other markets in Africa with MNP to which we could compare. Our general expectation was that take up would be heavy in the beginning, as anticipatory demand was fulfilled. Thereafter, it would slow to a reasonably steady pace, and subsequently grow proportionally to the market.
Variations could be caused by operators’ decisions from time to time to promote MNP as a means of attracting new customers, by seasonal factors, and by any service-affecting disruptions. 3 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 Chart 1 below shows the number of completed, aborted (unsuccessful), and blocked porting requests on a month-by-month basis. Ch ar t 1 – M o n th b y M o n th Por tin g Req u e st s Chart 2 below shows each request category’s cumulative numbers through the past year. 4 Mobile Number Portability in Ghana – First Year Report – July 18, 2012
Ch ar t 2 – Cu m u lat i ve Po r tin g R eq u e sts The total number of successful ports which have taken place in the first year of operation has reduced the per-port cost by nearly 70%. This efficiency of scale has validated the mobile networks’ decisions not to pass the porting cost on to the porting customer. It is important to remember that all mobile networks are active participants in the MNP process. Customers have ported numbers to and from each network. Table 1 below shows the ports to, ports from, net ports, and impact on each operator’s subscriber base at the end of the first year of operation:
A ir te l E xp r es so Glo M TN Ti go Vod a fon e Por ted In 44 , 74 2 30 4 7, 9 84 66 , 32 0 14 7 ,7 09 10 3 ,2 43 Por ted Ou t 38 , 24 4 72 2 42 5 19 1 ,6 81 79 , 47 9 59 , 75 1 Net G a in / ( Lo s s) 6, 4 98 (41 8) 7, 5 59 (12 5 ,3 6 1) 68 , 23 0 43 , 49 2 % of B as e 0. 24% -0 . 18% 0. 78% -1 . 13% 1. 82% 1. 56% Tab le 1 – To t al Com p le t ed Por ts b y Net wor k 5 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 One should not draw unsupportable conclusions from the above data.
There is a correlation between market share and ports out from a network simply because a customer can only port from the network they are presently on; a high number of ports out may not necessarily point to any particular problem at that network. The net impact on each network should be considered in the context of that network’s size. It is also possible that customers who port their numbers are above-average users, which would enhance the financial benefit of porting for the networks receiving such customers.
Also keep in mind that Glo launched their service nearly 10 months after MNP began in Ghana, hence their lower numbers. The net porting for each mobile operator is not yet large enough to have been the sole cause of any changes in marketplace rank which took place in the past year. Of the total completed porting requests to date, approximately 8. 3% represent numbers which ported more than once. On the average, those customers waited 89 days between their first and second ports. 93% of those customers ported back to their original network while 7% ported to a third network.
Less than 2% of the customers who ported multiple times did so three times or more. We infer from this information that most customers who ported their numbers were generally satisfied with their decision. We also point out that the number of successful ports is not the only criteria on which MNP success is judged. Each mobile operator has made changes in their operations in response to the enhanced competition MNP encourages, whether to attract new customers or to retain their current customers. It is not practical, owever, to determine with certainty to what extent these changes are attributable solely to the MNP environment. Performance Before entering into a discussion of porting performance, it will be useful to give a brief description of the porting process as implemented in Ghana: 1. 2. 3. The customer visits an agent or shop of the recipient network with his phone and ID card; reviews the porting process with the agent; signs the porting request form; and sends a free validation SMS to the PXS short code.
The agent, though the recipient network’s equipment, submits a porting request to PXS. Note: if the request is submitted but the validation SMS is not sent within 2 days, the request will be cancelled, or “aborted” by the system. Conversely, if the validation SMS is sent but the request is not 6 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 submitted within 2 days, the SMS will be removed from the system. In either case, PXS sends an SMS to the customer informing them that their request could not be processed. . As soon as the request matches with the validation SMS in the system, PXS checks the request to ensure that the number has not already been ported within the previous 30 days, and that there is no other pending request to port that number. Then PXS passes an authorisation request (“AREQ”) to the donor network and sends and SMS informing the customer that their request is being processed. 5. Upon receiving the AREQ, the donor network checks the number to ensure that it is an active account which has been open for at least 30 days, and hat it is not related to any fraud or theft report. If it passes these tests, the donor sends back to PXS an authorisation response (“AUTH”) approving the request. 6. Note: If for any of the few permitted reasons the request is not approved, the AUTH message from the donor indicates rejection of the request, and PXS notifies the recipient that the request is “blocked”. 7. Upon receiving an AUTH from the donor that the request is approved, the recipient sends an instruction request (“IREQ”) to commence the port. It then activates the customer’s new account and SIM. 8.
Note: If the recipient does not send the IREQ within 48 hours after the AUTH is sent by the donor, PXS will abort the porting request. 9. PXS sends the IREQ to the donor and at the same time, sends an SMS to the customer notifying them to change their SIM. At this point the porting request will be completed within 15 minutes. 10. The donor closes the customer’s account, deactivates his old SIM, and sends an instruction response (“IRES”) to PXS confirming it has done so. 11. PXS now considers the porting request to be completed, and it adds that customer’s number to the central list of ported numbers in Ghana.
PXS then sends a message to ALL networks in Ghana informing them of this new port, so that each of them will know they should send calls and SMS for that number to the recipient network rather than the customer’s original network. The MNP Regulations require that the recipient submit a porting request within 12 hours after the customer’s application; that the donor should respond with their AUTH within 4 hours after receipt of the AREQ from the donor; and as is also mentioned in the MNP policy, that the entire process should be completed in less than 24 hours.
However, from launch, porting in Ghana has been far faster than 24 hours, which compares favorably with most other countries. Even in the European Union, not all countries have yet reduced their porting times from 7 days to 1 day as required by EU regulation. 7 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 However, the MNP Steering Group was mandated by the MNP policy to find ways to reduce the total porting time in Ghana.
The goal is to ensure that the process is completed within the period of time that the porting customer is in the shop or with the agent of the recipient network. This would help to avoid any uncertainty on the part of the customer, improves their satisfaction, and reduces the workload on each network’s customer care staff. In July 2011, the first month of operation, the average time to complete a port was 5 hours, 21 minutes. Month by month, the average time reduced to 2 hours, 37 minutes in April, 2012.
When MNP began in Ghana, some operators had systems in place that handled the process communication with PXS automatically. Others could not be ready on time, and used live personnel to manually process each porting request through an online connection with PXS. At the time, NCA decided it was better to launch MNP in the market as soon as possible rather than to wait for those networks whose systems had not yet automated. In the first quarter of 2012, it became clear from examination of the data that properly-operating automated systems at each mobile network could produce much faster porting times.
The Steering Group adopted in April 2012 performance goals specifying how quickly each network should send their various responses to the system. By addressing each type of response individually, the total average time is reduced. At the same time, NCA made clear that all operators must complete their transition to automated port order processing. Data was gathered weekly to measure progress toward the performance goal. The goals were set by observing the performance of properly operating systems in respect of the three main steps in each porting request, and are described as follows: ? ? ?
After the AREQ is sent, the donor must send AUTH within 15 minutes at least 90% of the time and within 30 minutes at least 95% of the time After the AUTH is sent, the recipient must send IREQ within 15 minutes at least 90% of the time and within 30 minutes at least 95% of the time After the IREQ is sent, the donor must send the IRES within 15 minutes at least 90% of the time (Note that after 15 minutes, PXS automatically sends the IRES if the donor has not done so) If all these goals are met, then statistically, one would expect 81% of all ports to be concluded within 45 minutes after being submitted to PXS and 8
Mobile Number Portability in Ghana – First Year Report – July 18, 2012 matched with the validation SMS. However, we have seen that automated systems will generally send their responses within 1 to 7 minutes, leading us to believe that even shorter typical porting times could be achieved through this initiative. A further benefit to customers and the market in general is the consistency that would be achieved; the amount of time required to port would not vary significantly with the networks involved.
As the mobile operators made then necessary adjustments, average porting times dropped to 1 hour, 35 minutes in May 2012 and 1 hour, 24 minutes in June 2012. However, the most dramatic overall improvement was achieved in the first half of July 2012, as the remaining few operators completed their automation installations and adjustments. The most recent data available at the time this report was finalized indicated that all operators had complied with the performance goals, and that average porting times had dropped to between 7 and 8 minutes .
Nearly half of the requests were completed in 5 minutes or less. Therefore, provided that all operators continue to meet the performance goals and suffer no service disruptions, Ghana has achieved “on the spot” mobile number porting. Another important issue is the correct routing of calls and text messages to numbers which have ported. As described earlier in this report, each network maintains a list of ported numbers and the network at which they are currently located. When anyone in Ghana places a phone call or sends a text essage, their network will first check in their list of ported numbers. If the destination phone number is on that list, then the call or text will be routed to the ported number’s current network as indicated by the list. If the destination phone number is not on that list, then the network will route the call to the network at which that number naturally belongs. PXS maintains the central list of ported numbers and it sends immediate messages to all networks in Ghana whenever a number is added to or removed from that list or when the current network of a ported number changes.
If any network’s list is not identical to the central list, customers of that network will not be able to call or text to numbers which are caught by the discrepancies in the network’s list. This system is quite typical of MNP systems worldwide. Upon finding in December 2011 that certain networks were having problems maintaining their local ported number list, NCA issued a directive that each network must reconcile their local list with the central list on a weekly basis and report the results to the Authority.
For the most part, the challenges have been isolated and resolved. At this time, only one network has a persistent problem in that their system fails to incorporate the list update 9 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 messages from PXS into their local ported number list. NCA continues to press that network to work with its vendors to find an expedited solution. Porting request success rate represents another challenge.
Chart 3 below shows the history of the successful, blocked, and aborted rates since launch: Ch ar t 3 – Ab o r t ed , Co m p let ed , B lock ed Req u es ts Nor m a l ized to 10 0% The overall success rate of requests to date is 75. 2%, and most recently 78. 4% in June 2012. It has been as high as 83. 1% (April 2012). NCA’s view is that the completion rate should approach 90% as consumers become aware of the process and the mobile operators refine their systems and educate their field operatives.
Almost all blocked ports were rejected for the reason that the accounts were not at least 30 days old when the porting request was received. In the first few months of operation more ports were blocked on the basis that the account was not active, but a more detailed definition of what constitutes an inactive account largely resolved this issue. Recently, a software update at one network caused them to block some requests improperly, but each of these was identified and resubmitted for approval. 10
Mobile Number Portability in Ghana – First Year Report – July 18, 2012 Aborted ports are a more persistent problem. 95% of aborts are due to no validation SMS being received within the 2 days before and after a porting request is submitted. The usual causes have been failure of the field agents to ensure that the validation SMS is sent from the customer’s phone, or failure of the mobile operator to submit the porting request within 2 days after the SMS was sent, thus causing the SMS itself to expire.
However, the large increase in aborted requests in November 2011 was due to a technical problem at one network which began in late October, causing a large number of validation from their customers to PXS to be “lost”. When it was apparent the problem would persist for some time, NCA directed on November 16, 2011 a temporary SMS waiver procedure which was suspended on January 26, 2012, after technical tests indicated that network had solved its SMS problem, and was cancelled on February 10, 2012 when it was clear the abort rate was no longer being impacted.
As Chart 3 shows, the abort rate was high during February and March 2012. This was caused, for lack of a better description, by one network’s enthusiasm for the MNP process outstripping its resources. At the time, all of that network’s port ordering responses were generated manually, and many requests aborted because they were not entered into the system before the validation SMS had aborted, or because nobody there sent the IREQ within 48 hours after the donor had sent its authorisation response. This problem resolved when that network implemented and properly configured its utomation system in late March 2012. There will always be validation SMS aborts to some extent, due to variations in the customer-agent interaction. However, in NCA’s view, there is no excuse for any aborts to take place when the recipient network has failed to send the IREQ within 48 hours after the AUTH is sent by the donor. Even if an automated system misses a response, each network is required to have humans checking the system manually a few times each day to catch things that their automated systems (or those of the other networks involved) have missed.
Each time a request aborts due to lack of IREQ, it means that a customer trying to join a network was thwarted by someone at that network not doing their job diligently for two full days. Consumer Issues Any customer who wishes to change networks for any reason – dissatisfaction with prices or quality, attractive offers at another network, or simple curiosity – can do so without changing their phone number. All 11 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 that is required is to bring ID and phone to a shop or agent of the network he/she wishes to join.
It is important for the customer to read carefully the porting request form before signing. NCA has examined and approved porting request forms from each network, and has ensured that all the necessary information is there. It is vital for the customer to understand that when he or she agrees to port their number, they are leaving their old network entirely and joining a new network. The old SIM will stop working. Any credit left in the old account will be lost. Any phone numbers stored on the old SIM should be copied into the phone so they will not be lost.
If a customer has problems during or after the porting process, assistance and information should be provided by the recipient network – the operator he has joined or is trying to join. Failing that, NCA can be contacted as follows: Web site: Email: Phone: Facebook: http://www. nca. org. gh/40/125/Make-a-Complaint. html [email protected] org. gh 030 701 1419 MNP Ghana (group page) We have noted in the past year that most problems in the porting process are caused by missteps at the recipient network.
Customers experiencing difficulties should not assume they were caused by their current network obstructing the process. Very soon after MNP was launched, we began receiving reports of agents in the field misleading customers into porting when that was not the customer’s actual intent. In some cases, a customer’s number was ported when all they had requested was to get a new number on another network with the same last 7 digits as they had on their current network, a practice some call “prefixing”.
That is not porting – a process which rather brings your entire mobile number to a new network. Initially we believed these were “birthing pains” which would diminish as everyone became more familiar with the process. However, we find today that even after one year, various types of miscommunication (at best) or deception (at worse) are taking place in the field, primarily by agents who are authorized by the mobile operators to sell their products and services. Many people tend to rely upon verbal representations and do not even read the document they are signing.
Agents have been telling people who have no 12 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 intention to port that they are getting a new free SIM and both their old and new SIM will continue to work. It is apparent that what we face now is not a familiarization process, but rather some agents with an abundance of salesmanship and a shortage of ethics. There is a procedure for remedying such fraudulent ports quickly, and the networks have generally cooperated well in resolving such matters at customer’s request.
The total number of such resolutions is quite low compared to the overall number of porting requests, but any misrepresentation is still too much. We need prevention, not just cure after the fact. NCA has asked the networks to call their agents to order, but we have not yet seen sufficient progress. We have suggested that the Telecoms Chamber establish a system to share information between operators about agents who have misled customers, so that they can be removed from the system. We understand that the Chamber members support this idea in principle but have not yet taken any steps toward implementation.
It may be left to NCA to act decisively to resolve this problem if the operators cannot or will not do so. We may change the specifications for the porting request forms to include warning language in large fonts. We may require operators to provide NCA copies of signed porting request forms for every request in which fraud is alleged. We may call customers, agents, and their supervisors for hearings on each case. In the end, we may be forced to issue sanctions against operators who allow this situation to persist at unacceptable levels. The integrity of the process is at stake.
Looking Forward MNP is a permanent part of the telecoms landscape in Ghana. Chart 4 below shows how MNP has grown in the past year, and how it might grow based upon a simple arithmetic prediction method: 13 Mobile Number Portability in Ghana – First Year Report – July 18, 2012 Ch ar t 4 – Co m p lete d R e q u est s sin ce Lau n ch an d Pr ed ict ion th r ou gh 20 12 This does not represent an NCA prediction or expectation. The take up of MNP is always subject to the will of the consumer responding to both positive and negative competitive factors.
The most important point to take away is that the ability to change networks without changing numbers is a very significant consumer empowerment. NCA understands that MNP is not a substitute for the other regulatory and enforcement functions it performs in the in the industry. MNP requires new modes of thinking and operation across the industry, as each porting request involves a customer, a recipient network, a donor network, a central service provider, and all the other networks which must route traffic correctly after the port is completed.
This is far more complex than a simple interaction between one network and one of its customers. While PXS operates the central system and has contractual responsibilities to the mobile networks, it lacks any regulatory authority. It therefore falls to NCA to remain engaged in monitoring and mentoring MNP service in Ghana, as the only entity that has enforcement authority over all the participants, and it does so with the consumer at the forefront of its thoughts. 14 Mobile Number Portability in Ghana – First Year Report – July 18, 2012
Acknowledgments It is important to recognize the role that the mobile operators have played in this project. The introduction of MNP impacts almost every department in a mobile company. NCA appreciates this and acknowledges the contributions of those companies and their many commercial, legal, regulatory, technical, project planning, and IT personnel who have made it the success it is in Ghana. Special recognition must be given to the MNP Help Desk personnel at the mobile networks and PXS.
It is on their desks and in their email inboxes that every MNP challenge lands, and they work diligently and cheerfully with their counterparts at the other companies and with their own customer service, marketing, and technical departments to resolve each and every MNP issue that arises, but receive little of the credit. So in this report at least – NCA says “Ayekoo”. We also appreciate the support the project has enjoyed and continues to enjoy from the Minister of Communications and the NCA Board of Directors, without which MNP in Ghana would not have become the benchmark that other countries in Africa and elsewhere strive to match. 15