DWP - The case for 03 telephone numbers

On Tuesday, the Secretary of State for Work and Pensions announced that all telephone lines operated by her Department will be reviewed. Many of them use 0845 numbers which carry a subsidy to the Department.

This blog post is a summary of the full document which you can download by following the link at the foot of this post. I've put them together to explain why the 0845 numbers should be abandoned and replaced with ones from the 03 range.

There is a growing list of public sector bodies using 03 numbers, including the DVLA, NHS Change4Life and 12 police forces. Sir David Varney recommended 03 numbers, following his review of public services in 2006.


The DWP has recently set a precedent by making its 0800 numbers free to call from mobile telephones. It has done a deal with the mobile operators, who normally charge their customers a premium for calling “freephone” numbers. This is sterling work by the Department and it should now look at moving its 0845 contact numbers over to 03 ones.

However, Jobcentre Plus has recently introduced a new 0845 number which will, by the end of April, have taken the place of the local numbers of each of its branches. See DWP’s December edition of “In Touch”. Whilst one part of the DWP is moving forward, another is going in the opposite direction!

Why does the Department for Work and Pensions use 0845 numbers?

The DWP’s justification for using 0845 numbers is because more people pay less than those who pay more than a geographic or 03 call. This suggests that it has a rather blinkered view of the issues.

What are 03 numbers?

The cost of calling 03 numbers can be no greater that of ringing a “normal” geographic number and this rule holds for all landline and mobile operators’ services. There are no subsidies for call recipients either. The charge to the caller is the incidental cost of making a phone call and is like the cost of a stamp needed to send a letter. For more information, see Ofcom’s briefing What are…03 numbers?

Reason for change number 1: The cost of connecting a 0845 call attracts a premium, but BT’s retail charges are not allowed to reflect this. Therefore, BT varies from other providers…

Whether what the Department gives as its reason for using 0845 numbers is true or not misses the point. Retailers usually pass on the costs they incur in providing goods and services to end consumers and this is also the case with 0845 numbers.

A call to a 0845 number carries a premium or subsidy to the end recipient for which most call providers reflect in higher call rates. BT is the exception to this rule because it is limited on the margin it can take with 0845 calls by virtue of the “NTS Condition” regulation, but this does not apply when its customers call geographic or 03 numbers. Granted, a few other providers do mirror BT’s perverse discount by offsetting their costs elsewhere, but this is down to competitive pressures.

Any body which promotes 0845 as being cheaper is thereby promoting BT as its preferred call provider that its customers should subscribe to. A public sector service should not be showing commercial favouritism in this way.

Reason for change number 2: Citizens who pay more incur premiums far larger than the savings enjoyed by the alleged majority…

Before I proceed, I would like to make clear that I do not condone the DWP notion that it’s acceptable to impose premium charges on some, so as to offer discounts to others. However, if this is how the Department wishes to play it, then I am drawn to make the following observations.

The cost of calling a 0845 number is up to 3.4 pence per minute less than a geographic call from a BT tariff, which is the biggest differential (that I am aware of) for landline users. Mobile subscribers pay a premium of up to 40 pence per minute. With this in mind, I hope that the DWP gave the latter group a greater weighting when it worked out which group is the winner in this contest.

Citizens on the lowest incomes often rely solely on a mobile for their telecommunications and means that the DWP’s policy acts to penalise them the most.

Reason for change number 3: The DWP receives a subsidy from callers from its use of 0845 numbers…

The Department receives a subsidy directly from service users, a fact which is highlighted in the statement from the Contact Council (see the PDF). No amount of denial of receipt of a “revenue share” in the form of cash affects this process; it is by the design of 0845 numbers.

The DWP is wrong to levy a service fee in this way; it should be funded from the public purse.

Reason for change number 4: The DWP’s 0845 telephone numbering plan rests on regulation imposed on BT Retail, which is likely to be removed soon…

BT’s 0845 retail charges are not more than its geographic ones because of the NTS Condition regulation which was designed to facilitate the propagation of “value-added” services, such as pay as you go dial-up internet services. Ofcom intends to review the NTS Condition within a year and the result may well be that it will be done away with.

Should this happen, then the DWP will not be able to use its current defence of 0845 being cheaper for some. This is because 0845 calls will most probably cost either the same as or perhaps more than a geographic call.

Reason for maintaining the status quo: To allow customers of BT (and of a few others who mirror its perverse pricing structure) to benefit from a discount, thereby handing a competitive advantage to these particular private operators…

Some may be of the opinion that the Department is in the pocket of BT, and is helping it in its goal of dominating the market in residential telecommunications services, particularly in view of the following facts:

• That its chosen telecommunications service supplier is BT.
• The NTS Condition was introduced to allow “micro-payments” to flow to call recipients when most people made their calls with BT. The DWP disregards this as justification but benefits anyway and, crucially, chooses to take advantage of the side-effect whereby BT prices are abnormally low, thus handing it a competitive advantage.
• Other providers reflect the subsidy paid to the DWP in their retail prices, although a tiny few do decide to offset their costs elsewhere in order to compete with BT’s perverse retail discounts.
• The DWP alleges that it has its cake, but is silent about the fact that it eats it as well. That is, its callers pay less and at the same time it benefits from the subsidy from them.
• In response to a Parliamentary question on Wednesday, Work and Pensions Minister Jim Knight said that 70% of callers ring from a BT landline, which obviously means that the rest must call from another landline provider, a public payphone or mobile telephone. This raises the following:
  • Whilst analysis of callers’ phone numbers (CLIs) will show whether they called from fixed or mobile devices, how does the DWP know which callers ringing from landlines placed their call with BT and which didn’t?
  • Not everyone calling from a BT landline enjoys a saving. As the Minister pointed out, calls to 0845 numbers are “free” for those subscribed a BT Calling Plan which has an inclusive element that is engaged at the time of calling. Thus, the 70% figure includes both those who save and those for whom it makes no difference whether they call via a 0845 number or a geographic/03 one.
  • How does the Department factor in those who are ringing from a friend’s BT landline because of the prohibitive cost of making contact from their own mobile (or landline)?

Download full paper “DWP - The case for 03 telephone numbers” (PDF 74KB)