European Communications Office

ECC Work Programme Database

   
Work Item details
Reference FNI_07
Short Name Sub-assignment of numbers
Subject Distribution and implementation of E.164 numbers across the electronic communications supply chain

Related WI
Scope

In September 2017, the WG NaN Strategy Task Force suggested that PT FNI could look at studying the sub-assignment of numbers. PT FNI - based on a questionnaire -  came to the conclusion that in  most countries sub-assignment of E.164 (and in some cases E.212) is allowed or an accepted practice. In some countries there are  rules defined in the numbering regulations; in others sub-assignment is not explicitly addressed in the regulations; in a few countries  sub-assignment is explicitly forbidden.

Sub-assignment of numbering resources may be defined as the practice where all, or part, of unassigned E.164 number block is used by another provider on the basis of an agreement with the original assignee. Sub-assignment is different from number portability and the transfer between providers of an assigned number block which is authorised by the NRA. With the sub-assignment practice, the sub-assignee is allowed to provide to its clients the use of numbers received in sub-assignment.

The work-item has as first objective to create a common understanding of the concept of sub-assignment. Based on that the pro’s and cons of sub-assignment will be assessed. Also numbering regulations/good practices containing rights and obligations e.g. to address the identified problems will be developed with special focus on the finding that sub-assignment of numbering resources inevitably leads to a loss of control by the Number Plan Administrator.  Enforceability of the proposed regulations will also a special point of attention.

During a web meeting on 17 September 2018, PT FNI participants progressed work on a Draft ECC Report on the sub-assignment of E.164 numbering resources. During the web meeting the concept of number hosting was discussed in detail. It had previously been agreed that number hosting should be outside of the scope of the sub-assignment report. However, during the discussion it became clear that number hosting raises the same concerns for CEPT administrations regarding transparency in the assignment and use of E.164 numbers and it was agreed to broaden the scope of the report to also include hosting. It should be noted that in the case of hosting, the lack of transparency is not caused by sub-assignment but by the agreements primary assignees (or sub-assignees) enter into with other network operators to have their numbers hosted.

Deliverable ECC Report
Responsible group WG NaN - NaN PT FNI
Start date 22-11-2017
Target date 28-11-2019
Public Consultation 23-05-2019
Regular Work Item False
Comments
Keywords sub-assignment, E.164, E.212, number assignee, secondary assignment
Worked by PT FNI
Contact Freddie McBride (freddie.mcbride@eco.cept.org)
Status In Progress
Triggered By Italy, Portugal, The Netherlands, Belgium, UK, Latvia, Sweden
Progress Report Work item adopted at the 15th WG NaN meeting (Bucharest, 21-23 November 2017)
First draft presented and discussed at web meeting on 13 March 2018
A first draft of the report was discussed in Riga (17-18 April 2018)
ECO produced a new version which will be discussed at PT FNI Lisbon (19-20 June 2018)

During a web meeting on 17 September 2018, PT FNI participants progressed work on a Draft ECC Report on the sub-assignment of E.164 numbering resources. During the web meeting the concept of number hosting was discussed in detail. It had previously been agreed that number hosting should be outside of the scope of the sub-assignment report. However, during the discussion it became clear that number hosting raises the same concerns for CEPT administrations regarding transparency in the assignment and use of E.164 numbers and it was agreed to broaden the scope of the report to also include hosting. It should be noted that in the case of hosting, the lack of transparency is not caused by sub-assignment but by the agreements primary assignees (or sub-assignees) enter into with other network operators to have their numbers hosted.

The scope of the work has been redefined as follows:

For certain market players wishing to offer electronic communications services (ECS), requesting numbering resources from the CEPT Administration may be a high threshold in view of the complexity of the procedures and/or the numbering fees involved. Moreover these numbering resources have to be implemented by other ECS providers, which is time-consuming and may not be an obvious process for a new assignee. That is why these market players may prefer to outsource this activity to third parties who have numbering resources which are already assigned and implemented at their disposal. This means that an ECS provider, with an existing assignment of numbering resources, puts all or part of those numbering resources at the disposal of another ECS provider as a service in order for the latter to provide ECS to its customers. This is called sub-assignment and it entails both advantages and disadvantages. On the one hand the market is made more competitive by allowing more players to access the market but on the other hand CEPT Administrations lose transparency and control over which parties actually undertake the obligations and conditions of use associated with the numbering resources.
Similar issues of transparency and control also arise with the emergence of number hosting services. Number hosting may be described as an arrangement entered into between a primary assignee (or a sub-assignee) and a hosting service provider. The hosting service provider offers wholesale network services to the assignee and the arrangement may or may not be known to the numbering plan administrator.
When a primary assignee of a block of numbers goes out of business the effect of sub-assignment and number hosting may vary. Typically when a primary assignee sub-assigns all or part of a numbering block it offers wholesale network services as part of the package under a commercial agreement. Therefore if the primary assignee goes out of business then the customers of the sub-assignee will also be disconnected.
With a hosting arrangement, it is possible for a primary assignee to go out of business and for its customers to stay connected as the network facilities are provided by an alternative service provider and interconnection contracts with other ECS providers may remain in place.
Both cases present transparency challenges for regulators. For example, who has rights of use of the numbers, who provides the network facilities, who has the regulatory responsibilities associated with the numbers and who fulfils those responsibilities?
This report studies the concepts and different variations of sub-assignment and hosting. To this effect, the relationship between the involved parties is carefully examined, namely the relationship between the ECS provider who was assigned numbering resources by the CEPT Administration (“the primary assignee”), another ECS provider who received the numbering resources through a sub-assignment (“the sub-assignee”) or the hosting service provider offering primary assignees and sub-assignees hosting services. The report also examines the rights and obligations of each party. Furthermore, the report examines the advantages and disadvantages of both practices and the enforcement challenges that they present to CEPT Administrations. In conclusion, it considers whether a possible harmonisation of the current approaches may reduce any negative effects to a minimum and presents regulatory guidelines to assist CEPT Administrations meet the challenges identified.
To inform this report, a survey of CEPT countries has already been carried out in relation to sub-assignment. A further survey may be needed for number hosting.