ARCEP launched a public consultation on a new draft amendment to the National Numbering Plan. The public consultation is opened until 18 February 2022. These new provisions aim at modernizing the framework for the allocation and use of numbering resources.
Since 2018 the National Numbering Plan has undergone numerous revisions. This new draft proposed by ARCEP tends to meet the new uses and needs of users and operators. This document also brings some changes taking into account the transposition into French law of the European Electronic Communications Code.[1].
Operators - or any interested actor - are invited to send their contributions before 18 February 2022, and more specifically on the 34 questions posed by ARCEP.
Among other things, ARCEP plans to adopt the following measures:
ARCEP plans to reserve a new category of 09 numbers for exchanges between technical platforms and mobile subscribers. ARCEP specifies that the new category of 09 numbers could, for example, be used to establish message conversations between a retailer and its customer, or for very short-term use of telephone numbers for certain temporary contact situations via a platform (deliverers, VTC drivers, etc.).
This measure is also in line with the emergence of new mobile uses. Indeed, the regulator wishes to reserve the use of 10-digit mobile numbers beginning with 06 and 07 for interpersonal communications (between two people) in order to avoid any risk of shortage of these numbers. This measure will make it impossible in practice to use mobile numbers for customer relationship management. The impact for operators and their customers is major. However, no transitional provision is foreseen.
While the Council of State (“Conseil d'Etat”) - France’s highest administrative court - had ordered the repeal of similar previous provisions of the National Numbering Plan in its decision of 12 February 2021; a law of 15 November 2021[2] has explicitly given ARCEP the power to regulate the conditions of use of numbering resources by automated systems. ARCEP can now specify: (i) the categories of numbers that cannot be used as caller ID to be presented to the recipient for communications made by automated calling and messaging systems and (ii) the measures that operators may implement to interrupt the routing of calls and messages.
It is within this context that ARCEP foresees in its draft revision of the Numbering Plan that certain territorialized numbers (geographic numbers, multipurpose numbers, multipurpose numbers used for exchanges with a technical platform and 10-digit mobile numbers) cannot be used as a caller ID presented to the called party for calls or messages sent by automated systems.
ARCEP also specifies the exceptions to the prohibition on the use of automated systems. ARCEP proposes that this prohibition does not apply to automated calling and messaging systems:
In response to the growing demand for numbering resources, particularly as a result of new uses, ARCEP is proposing a series of measures to enable more efficient management of these numbering resources by further rationalizing:
In addition, the draft revision of the National Numbering Plan also includes other provisions concerning:
The document submitted for public consultation until 18 February 2022 is available here.
[1] Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code.
[2] Law No. 2021-1485 aimed at reducing the environmental footprint of the digital economy in France