Dear CMA BT / TalkTalk inquiry team,
I am writing on behalf of WIRES (Web Infrastructure Rights for Everyone in Scotland), a volunteer-led campaign for affordable, reliable connectivity in Scotland. This representation covers both the competition question and the public interest ground concerning customers who are or may be vulnerable.
We accept that keeping 2.5 million customers connected was better than letting TalkTalk fail. Our concern is what the transaction does to prices and choice for low-income households afterwards. We ask the CMA to reflect the following points in its report and advice to the Secretary of State, and that any clearance is subject to conditions addressing them.
1. Protect existing TalkTalk customers on price
TalkTalk has competed largely on price. Its customers include many households for whom a few pounds a month decides whether they stay online. Ofcom's advice to TalkTalk customers on 5 October says: "There will be no change to your price, contract or how you access billing." It goes on: "If anything changes in future, BT will contact affected customers directly and provide clear notice and support." That is an assurance with no end date, and it leaves future changes open. We ask that the protection on price and contract terms is made a condition of any clearance, for a defined period. We also ask that customers are not moved to dearer BT Group tariffs without a clear choice, and that any customer who is moved can leave without exit fees.
2. Guarantee access to a social tariff
TalkTalk does not offer a social tariff: it is absent from Ofcom's published list. Its low-income customers can only get one by switching provider, which can mean paying to leave their contract. Ofcom's own research finds that fewer than one in ten eligible households take a social tariff, and around seven in ten are unaware they exist. BT offers one. TalkTalk customers on qualifying benefits should be told about it directly and able to move to it without penalty.
3. Weigh the loss of a low-cost competitor
BT Group already owns BT, EE and Plusnet, and Openreach, the network most other retailers depend on. We ask the CMA to examine the effect on the budget end of the market specifically, and on the smaller providers supplied through PlatformX, whose wholesale terms now sit with the group they compete against.
4. Recognise that the effect is greater in rural Scotland
In the areas Ofcom classes as "Area 3", competing networks are unlikely to be viable, so the main competition consumers have is between retailers on Openreach's lines. Consumer Scotland's analysis is that more than 30% of Scottish postcodes fall into Area 3, against 18% across the UK. Removing an independent retailer matters most where there is no other network to turn to.
5. Protect vulnerable customers through any migration
This goes to the heart of the public interest ground on supply to vulnerable customers. No customer who relies on a landline, telecare alarm or text relay should be migrated without direct contact and support.
We would be glad to provide anything further that would help.
Yours faithfully,
William Ellis
WIRES — Web Infrastructure Rights for Everyone in Scotland
hello@wires.org.uk
https://wires.org.uk
Sent by email to the CMA's BT / TalkTalk inquiry team on 6 October 2026. This is the full text.