Introduction

The Commission for Complaints for Telecom-television Services (“CCTS”) is Canada’s national and independent organization dedicated to resolving customer complaints^[1] about telecommunications and television distribution services. As of December 31, 2022, there are 311 service providers, represented by 432 customer-facing brands that participate in the CCTS (referred to as Participating Service Providers or “PSPs”).

As participants in the CCTS, PSPs are required to carry out the requirements of the CCTS’ PSP Public Awareness Plan,^[2] comply with the Procedural Code, and meet their financial obligations (e.g. disclose their retail revenues and pay CCTS fees). The CCTS actively monitors compliance with these participation requirements and engages with non-compliant PSPs to bring them into compliance.

Since 2016, the Canadian Radio-television and Telecommunications Commission (“CRTC”) expects the CCTS to monitor and encourage PSP compliance with its obligations, and enforce these obligations by using the CCTS’ available tools such as publishing the names of non-compliant PSPs in a prominent manner.^[3]

In 2023, the Government of Canada issued a new Policy Direction to the CRTC, with specific direction to enhance and protect the rights of consumers in a number of areas. This direction includes strengthening the ability of the CCTS to improve compliance with the CCTS’s rules and increase public awareness of the CCTS’ complaint-resolution process.

The CCTS’ compliance monitoring program remains integral to fulfilling the CRTC’s expectation and the Government of Canada’s policy direction.

In general, when we identify a non-compliance issue, we work with the PSP on an individual basis to explain the requirements, our expectations, and how the PSP can become compliant.  We find that many PSPs want to work with us to rectify any issues of non-compliance.  In some circumstances, we invest considerable time and effort to educate a PSP and work with it to bring it into compliance.  In the rare circumstances when the CCTS exhausts all its tools and the PSP fails to comply with major or long-standing non-compliance issues, the CCTS terminates the service provider as a participant in the CCTS.^[4] Since the CRTC mandates participation by the provider, we refer the matter to the CRTC for further action. The CCTS does not resort to this enforcement measure until after we have made every effort to get a PSP to rectify its major non-compliance without success.

Each year, the CCTS publishes an annual Compliance Monitoring Report discussing the activities and issues we observed in the preceding year.  This report also highlights the enforcement measures taken and publicly identifies the names of service providers who failed to join the CCTS when required to do so, PSPs with major non-compliance issues, and any PSPs whose participation was terminated.

The CCTS strives to continuously improve compliance activities based on feedback from our stakeholders, including the PSPs, CRTC and consumers.  We prioritize communicating with PSPs on an individual basis to increase PSPs’ understanding of their participation requirements and to bring non-compliant PSPs into compliance.  As a result, our compliance efforts can take a considerable amount of time and effort.