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UK Vodafone Compliance Notice


This notice has these elements to it.

  1. Restating the Vodafone Payforit (PFI) Mandate
  2. The removal of the Co-Reg Exemption to the PFI mandate
  3. The evolution of Red Cards issued by Vodafone
  4. The removal of the 120 day inactivity rule
  5. Please be reminded that Vodafone re-affirmed the PFI Mandate on 11.4.13 which states:

Vodafone Limited requires that if a service is discovered and/or delivered  by means of WAP/WEB sites, (discovery is not limited to but includes; online banners, search terms, QR codes) that the Payforit (PFI) Scheme rules using the Vodafone Charge to Bill platform(CTB) are used and adhered to. No PFI accredited customer shall be transferred over to Premium SMS billing. Failure to comply is a breach of your premium rate Services Agreement.

An example of a service that should be converted to Payforit are quiz and competition services that ask questions online and should be monetised using PFI.

The previous re-statement of the PFI mandate (26.11.15) has led to a view by some Merchants that it was an invitation to construct promotional mechanisms which intend to subvert the PFI Mandate. The prime example of this is to use a survey site to create a mechanism to collect names, MSISDNs and email addresses, then email the Vodafone customers with an offer, in that offer there is a link leading to an online promotional material and a PSMS competition entry. Vodafone has issued warnings informally for a number of weeks and has used the white card process to advise Merchants and Aggregators that this activity of email campaigns and lead generation sites falls outside of the Vodafone PFI Mandate. For the avoidance of doubt these services are consumed (delivered) on line and therefore must use a Payforit two step mechanism. 

In support of this Vodafone gives notice that going forward there are no exemptions for services that run inside the Co-Reg website page as agreed with industry last year. To the date of this notice Vodafone has been unable to identify services running on the industry agreed Co-Reg pages. Therefore Vodafone removes the Co-Reg exemption from the 1st November 2016.

Moving forward services found outside of agreed exemptions to the PFI mandate will receive Red Cards.

Further to this Vodafone gives notice that the conditions of the Red Card issued by Vodafone will change from the 1st November 2016. The current system assumed that Merchants were working with Vodafone to improve compliance and meant that the Red Card process was; find, suspend, fix and relaunch. It transpires that upon analysis of Red Cards that have been issued, that the same merchants are being re-issued similar Red Cards within a fortnight. To ensure that Merchants are have time to stabilise the situation, Vodafone will issue Red Cards with a minimum 10 day suspension applied. This minimum 10 day suspension from the Vodafone network will stop new acquisition and revenue accrued in this period will also be clawed back.

Vodafone also confirms that the 120 day inactivity rule currently in the PFI code of practice will be no longer form a part of the Vodafone compliance code of practice.


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