NFCC guidance for Public Switched Telephone Network (PSTN) migration

Background

The telecoms industry will retire the Public Switched Telephone Network (PSTN) and Integrated Services Digital Network (ISDN) by January 2027. The telecoms industry will replace these services with new digital technology that uses an internet connection, referred to as Voice over Internet Protocol (VoIP), Digital Voice or All-IP telephony.

The PSTN is the analogue copper network that has historically delivered landline services. It also provides connectivity to over 300 other types of devices, such as alarm systems, many of which would pose risks to life if they failed. The upgrade of the UK’s telephone lines is not a government programme and does not result from a government decision or policy. Instead, this change is driven by necessity.

The copper network is increasingly unreliable and becoming more difficult to repair. The telecoms industry has therefore made the decision to retire this network and migrate landlines and linked devices onto digital networks.

How are fire and rescue services impacted?

For the vast majority of consumers and businesses, this change will be straightforward. Nobody should lose their landline service because of this change and telecoms companies will continue to be bound by the same regulatory obligations as they are today. Not all fire and rescue services will be affected by all of the issues outlined below, and in many cases, it is likely that the only required course of action will be to review and confirm that required changes have been made.

Furthermore, most multi-line telephony for businesses, public bodies and organisations will already have been moved away from the PSTN. A lot of specialist uses of the PSTN have also been moved to IP or cellular technology for the same reasons.

However, there are specific ways where the migration might impact fire and rescue service duties and responsibilities, as well as day-to-day operations. The sections below outline some of the known potential issues, as well as actions to prepare for the migration.

Potential disruption to mobilising systems and incoming emergency calls

Many fire and rescue services will currently be using ISDN/PSTN lines into their fire control for 999s, admin lines and so on. PSTN is also commonly used as the Secondary Bearer for Station End Equipment (SEE) and as the main telephone line into station; these will require replacing. Some fire and rescue services have already moved to fibre options, 4G or GSM solutions.

There may be disruption to incoming emergency calls to fire and rescue services and the reliability of emergency call information from alarm receiving centres (ARCs). It is difficult to quantify what this disruption will be, but it may include a delay to the call or incomplete information. In particular, emergency calls from ARCs monitoring dispersed Telecare alarm systems in single private dwellings, or other forms of specialised housing using monitored Telecare systems, may be passed with very little information due to the nature of the equipment being used. Some of these are outlined below.

Some training might be required for prevention, protection, response and mobilising staff to raise understanding of the impact on their role.

The following premises types in particular may be particularly susceptible due to analogue to digital issues:

Specialised housing

There are numerous ways in which social housing providers may be impacted by the PSTN migration. For example:

Alarm devices in sheltered and supported schemes may need to be changed
Small telephone systems in remote offices, for example on schemes, will need replacing
Lifts will need to be checked to ensure emergency alarms are digitally compatible
Intercom systems or access systems may need to be replaced

It is also important to check whether your office telephony services, including fax and franking machines, will be impacted, or whether they have already been migrated.

Dispersed Telecare alarms

Telecare monitored alarms used to support the care and mitigate the risks for vulnerable citizens. Most of the equipment used is based on the analogue system. There are a number of ways in which a call from this type of system might fail to reach the ARC, be delayed or have no voice capability. In addition, during a power cut, a signal will not be passed at all.

Awareness raising and vulnerable citizens

Fire and rescue authorities and local authorities are uniquely trusted voices in local communities. You may wish to consider providing information locally about the PSTN migration, both internally and externally, to help ensure the public are aware of what they need to do. However, there is no obligation on fire and rescue authorities or local authorities to contribute to awareness raising.

Ofcom has General Conditions in place to ensure that providers give sufficient consideration to the particular needs of people with disabilities and people whose circumstances may make them vulnerable. In relation to migration to VoIP specifically, Ofcom expects providers to assess customer needs and offer help with migration if necessary.

Some communication providers have asked local authorities to help them communicate the migration, particularly towards vulnerable customers. In response, some local authorities have decided to work to raise awareness locally, for example by publishing information on their website or providing pamphlets in public spaces, such as libraries.

There are significant amounts of available collateral to use, in case fire and rescue authorities want to work actively to raise awareness. In particular, the Local Government Association (LGA) has prepared a Digital Switchover Partner Toolkit for councils and partners to use. The toolkit contains assets aimed at residents to raise awareness of the upcoming switchover.

Suggested actions:

Audit your estates and equipment and ensure the necessary changes and alternative network solutions are implemented
Consider monitoring for a potential increased numbers of false alarm signals
Consider if you would like to work actively to raise awareness
Discuss with your communications provider. They should be able to provide additional information, such as when they plan on conducting residential migrations in your area. Some providers may also offer data sharing agreements, whereby local authorities and providers can work collaboratively to identify vulnerable customers and design suitable connectivity solutions for them.
Consult existing material and get information on best practices. The LGA’s digital switchover hub and Local Government Digital Switchover Working Group may be good places to start.

Non-telephone devices using the PSTN

A large number of devices and services rely on the PSTN for connectivity. Many of these are used by fire and rescue services.

Mobilising equipment
CCTV
Electricity monitoring devices
Gas monitoring devices
Lift communications
Contracted services

Suggested actions:

Contact your communications provider. Understand who provides telecoms services to your fire and rescue service. Bear in mind that different departments may use different providers. Contact your provider and speak to them about their plans for the PSTN migration and what support they can provide you.
Set up channels and forums to collaborate. Bringing together all affected departments will help ensure that nothing is missed and provides an opportunity to share best practice. The migration could be approached as a business continuity issue. Affected departments may include:
- Estate management
- Risk management
- Incident command
- Fire control
Share good practice; discuss challenges and learn from the approaches other fire and rescue services are taking
Join the LGA’s digital switchover working group
Consider appointing a project manager or single point of contact. Where possible, having a designated person leading the programme will help to co-ordinate activities and share learning.
Seek senior and political level buy-in. By proactively informing your fire and rescue service leadership of the risks involved with not taking action, you are more likely to receive support for a co-ordinated approach across the service and local authority.
Audit your estate. Understand where there is connectivity, which suppliers are used, if affected devices or services are still required, and whether they are IP ready. Many affected devices or services may not be immediately obvious. The audit process may need to be an iterative process – ask your communications provider for advice on auditing the services they provide.
Build a migration plan. Understand the important dates, and work with communications providers and other suppliers to build a migration timeline. Devices and services that are business critical or carry other safety implications should be identified and migrated first. It is also worth highlighting that some new solutions will not be a like-for-like replacement for existing applications; for example, it may be preferable to connect replacement services using an internet connected solution instead of a digital phone line.
Test your equipment as required. Some network operators, including Openreach and Virgin Media, run test labs where stakeholders can test the VoIP compatibility of their equipment across multiple providers and connections. Reach out to your communications provider to learn more.

Security and fraud

We are aware that there have been scam attempts associated with the PSTN migration, whereby adverse actors have impersonated communications providers or other suppliers, and have asked consumers or businesses to provide them with money in exchange for getting their services migrated. The LGA has noted that some scammers are also impersonating local government officers to gain access to residential homes.

We encourage all fire and rescue services to be vigilant and to report suspected scam attempts to their local trading standards team in the first instance, and to the National Trading Standards Scams Team who may then be able to undertake enforcement action. The National Trading Standards Scams Team undertake enquiries into mass marketing fraud, involving the use of mail and telephone and can use a variety of methods to disrupt scammers, such as removing bank accounts or their ability to print materials. Email the team to report cases. Councils can report scam cases to scamsteamadmin@surreycc.gov.uk.

The PSTN replacement, VoIP technology, works by transferring data over a broadband connection. VoIP technology means that phone calls are provided as another broadband service, instead of over a separate traditional analogue telephone system. Most calls will be provided over communications provider ‘PSTN replacement’ networks, which have no exposure to the public-facing internet. However, some calls may be routed over the wider internet, which could lead them to be potentially susceptible to interception and compromise. VoIP can be secured using basic cybersecurity methods and good practice, similar to other policies and practices to protect important data that likely exists for your fire and rescue authority.

The PSTN switch-off is an opportunity to tackle the use of Calling Line Identity (CLI) spoofing which is central to many attempts of telecoms fraud, such as phishing attempts. VoIP technology offers the opportunity to introduce new identification protocols that verify the caller ID of anyone making a call, which will limit impersonation attempts. As such, the PSTN migration will lead to an overall long-term decrease in telecoms fraud.

Suggested actions:

Consult your IT experts regarding the configuration of replacement solutions for PSTN-enabled devices and services. Follow existing NCSC principles for establishing secure communication services.
Engage communication providers and other suppliers to discuss the security of new services. The telecoms industry has already established standards to effectively limit any cybersecurity risks associated with digital voice calls.
Ensure frontline staff are aware. Train staff and ensure they are aware of the switchover and understand how to report concerns.
Be vigilant against scam and fraud attempts. Speak to your communications providers and suppliers about how they will identify themselves; report anything suspicious to the police.
Consider communicating the risk of scams to staff, citizens and local businesses. You may wish to use local communications channels to raise awareness of the switch-off and to ensure consumers and businesses understand the migration process. We recommend focusing on those who may be targeted by scammers, such as elderly or vulnerable people, and to use language which reflects the criminal nature of the issue. LGA guidance about scams provides a good overview.

Power resilience

The analogue transmission landline carries a low voltage power connection directly from the telephone exchange, which is sufficient to power some basic corded handsets without needing to plug them into a power socket. This means that in the event of a local power cut, these corded handsets will continue to function as long as the telephone exchange still has power. Only corded phones have this capability; cordless phones, such as DECT phones, which are common in homes need mains power to work^[1], so will not work in the event of a power cut at the property.

Digital landlines need a broadband connection to work, which means handsets and routers must be mains powered constantly, and they will not function in a power cut unless there is a backup power system such as a battery or generator.

Telecoms companies are required by Ofcom to take all necessary measures to ensure uninterrupted access to emergency organisations for their customers, including in the event of a power cut. Ofcom issued guidance in 2018, Protecting access to emergency organisations when there is a power cut at the customer’s premises, covering how telecoms companies can fulfil this regulatory obligation in light of the migration to digital landlines. The guidance was issued following a consultation with industry stakeholders and the general public, using data from Ofgem on the average length of power outages in the UK.

The guidance states that providers should have at least one solution available that enables access to emergency organisations for a minimum of one hour in the event of a power outage in the premises. This should be provided free of charge to customers who depend on their landline to make emergency calls in a power cut.

Suggested actions:

Assess your power resilience requirements and capabilities. In particular, assess if any parts of your estate are particularly crucial and how they would be affected in a power cut.

^[1] The handsets have batteries, but the base station in the property that connects to the phone line needs mains power

Mobile coverage and 2G and 3G switch-off

For most residential customers, telecoms companies recommend using a mobile phone as a backup in case of a power cut. For consumers who do not have a mobile, or live somewhere where there is no signal, their landline provider should offer them a solution such as a battery back-up unit. This will mean that they can still make emergency calls during a power cut. If residential customers have additional needs or live in an area of poor connectivity, they are advised to make their communications provider aware.

Fire and rescue services may wish to further consider their power resilience requirements and capabilities. For example, are there particular buildings, processes, services or devices that are of particular importance and where power resilience is paramount. What are the ways in which suppliers and communications providers offer power resilience or alternative connectivity in the event of a power cut.

Some devices and services rely on 2G or 3G mobile connectivity as a means of providing connectivity, either as a primary solution or as a backup. GOV.UK has published A joint statement on the sunsetting of 2G and 3G networks and public ambition for Open RAN rollout as part of the Telecoms Supply Chain Diversification Strategy. The UK’s mobile network operators have confirmed to the Government that they do not intend to offer 2G and 3G mobile networks past 2033 at the latest, with the last 3G network being closed by the end of 2025^[1].

All four mobile network operators have now confirmed when they will begin turning off their 3G networks, with BT/EE, Three and Vodafone having already begun the phased shutdown of their 3G networks, before retiring them in 2024. VMO2 will begin switching off its 3G network in 2025. As such, fire and rescue services may wish to consider solutions that utilise another means of connectivity, to avoid needing to make upgrades in addition to those related to PSTN migration.

While Ofcom has no formal role in the switch-off process for the 2G and 3G networks, they want to ensure that customers are treated fairly and can continue to access the services they need. In the Ofcom 3G and 2G switch-off February 2023 publication, they set out several expectations of the mobile network operators, including communicating with and providing support to customers, well in advance of when their legacy networks are being retired.

Each of the mobile network operators have set out advice to their customers on their websites on 3G switch off plans, including setting out what customers might need to do to prepare for switch-off, along with what support is available for vulnerable consumers.

Ofcom have also published Switching off 2G and 3G and 2G networks: advice for IoT and third-party device suppliers, who have a responsibility of ensuring continuity of services, such as Telecare, once legacy networks are retired. This sets out things that Ofcom suggests they should consider doing to support users, including:

Communicating with customers to make them aware of any changes that may be required and by when they may need to happen
Taking any necessary steps to identify customers who could be affected by the switch-off, and minimise any associated risks

We are also beginning to see specific sector bodies publish advice to their members such as the Fire Industry Association publication, 3G is being switched off: Are you ready?

It is worth noting that none of the mobile network operators have set a specific date for 2G switch-off. We expect the mobile network operators will start making plans to switch off their 2G networks after they have switched off 3G networks.

Suggested actions:

Awareness raising. The 2G and 3G switch-off may not be widely known. Consider using internal communications channels to ensure preparations are in place ahead of the mobile 2G and 3G switch-off and explain the relationship between the PSTN migration and the mobile switch-off programmes.
Discuss power resilience and connectivity with your communications providers and suppliers. Understand how your devices and services will react in a power cut, any resilience solutions on offer, and if they are reliant on 2G or 3G connectivity.

^[1] Further details for customers on the timing of mobile network operator 2G and 3G switch off are provided in the Ofcom publication, Switching off the UK’s 2G and 3G mobile networks: what you need to know

Intruder alarms and fire alarms

There are two main types of alarm, intruder alarms and fire alarms. Each of these types can be further divided into monitored or unmonitored.

Unmonitored alarms activate when triggered and produce an alert, usually in the form of a siren. In the case of a fire alarm, this acts as a prompt to evacuate the building. Monitored alarms are connected to and monitored by ARCs. ARCs are responsible for responding to activations from alarm systems.

In the case of intruder alarms, ARCs will also contact a keyholder and the police, if a police response is part of the agreed service. For a response to be triggered, the police require alarm confirmation – this is when further evidence of an intrusion occurs, for example passing a further alarm signal, or audio or visual confirmation.

The monitoring technology usually works in one of two ways. Either it is provided by a third-party managed signalling provider, such as BT Redcare or CSL, or sent directly to the ARC by a digital communicator as part of an on-site alarm system. Historically, the industry has relied on analogue phone technology as a primary path. Managed services tend to use mobile network SIM technology as their primary path with the secondary path being a dial up connection.

Some legacy alarm products rely on all copper end-to-end connectivity and will need to be withdrawn. Others may face issues with moving to VoIP technology for other reasons, such as power resilience.

Suggested actions:

Audit your estate for alarms. Understand:
- Where alarms are installed
- Who the supplier is
- Which model is used
- Who the responsibility lies with
- Whether the alarms are still required
Engage with your alarm supplier. Understand how their service provision may be impacted by the PSTN migration. More information is also available through the British Security Industry Association (BSIA), the trade association for the professional security industry in the UK.

Lifts

Every lift has an alarm, usually a button that connects to a rescue service via a preprogrammed phone number. It works by using an auto-dialler – a piece of hardware that sits on top of the lift car and is plugged into the phone line using a master socket. The rescue service is often, although not always, run by the lift company and both the lift company and the lift owner have different responsibilities.

As the industry changes to VoIP technology, the lift maintenance companies, the lift owners, and communications providers will have their part to play and it is vital that everyone knows what their responsibilities are.

Suggested actions:

Audit your estate for lifts. Understand:
- How many you have
- Where they are situated
- The relevant provider
- Their model
Identify and speak to your lift provider. Understand:
- The connectivity solutions for your lifts
- Whether a back-up solution is required
- Any other complications, such as if your lifts are situated in areas with poor mobile reception
Plan for procuring replacement services. We have received anecdotal information that there is a shortage of equipment and skilled lift engineers; build in contingency plans to your timeline.

Door entry systems

Door entry systems, also known as access control systems, are designed to regulate access to restricted areas, allowing only authorised personnel access into a given space. There are various kinds of door entry systems, ranging from keypad door entry systems to biometric door entry systems.

Door entry systems and intercoms have traditionally run on analogue phone lines. Modern systems that already run on VoIP lines will be unaffected by the PSTN switch off. However, older intercoms connected to analogue lines will stop working; as such, all live door entry systems using PSTN lines will require adaptation or replacing.

Suggested actions:

Audit your estate for door entry systems. Understand:
- Where door entry systems are installed
- Who the supplier is and which model is used
- Whether the systems are digital or analogue
Depending on the age of the device and the contract you have with your service provider, there may be three options available:

1. Switch devices to an IP mode, if available
2. Speak to your service provider about adapting any existing devices to digital lines. An example of how to do this would be to use an analogue telephone adapter (ATA) to convert analogue device signals into digital.
3. Upgrade to a VoIP intercom system – it is worth bearing in mind, if devices need replacing, that 2G and 3G services will also have a limited life span

If in doubt, contact your service provider for more information on the operating parameters of your devices.

Fax machines

Traditional fax machines use modems to transmit and decode signals over the analogue lines of the PSTN. After the migration from PSTN to VoIP, traditional fax machines cannot be guaranteed to work.

In addition to this, Parliament agreed at the start of 2023 to remove fax services from the universal service obligations as detailed in the Ofcom Statement: Removing fax from the universal service obligations on BT and KCOM.

Ofcom has indicated that a number of alternatives to fax are available including email, picture messaging, document management platforms, online secure file transfer services and electronic signature services.

However, there are alternative fax services that will continue to work after the PSTN switch off. Digital cloud fax services allow you to send and receive faxes using a method whereby documents are sent over the internet, instead of a traditional phone line. This may be an option that enables you to retain fax services after the switch off.

Suggested actions:

Audit your estate for fax machines. Understand:
- How many you have
- If anyone in your organisation relies on them
Speak to people within your organisation. If there are people within your organisation who do still rely on fax, ensure they are aware of the PSTN switch off and any available replacement for traditional fax.
Plan for procuring replacement services. As noted above, there are a number of available replacements for traditional fax, whether internet-based fax services or otherwise. You should identify any business need for fax and work to identify a suitable alternative.

Contactless payment systems

Electronic Point of Sale (EPOS) systems work together with card machines, sometimes referred to as PDQs, to create a functioning payment system. Hundreds of thousands of business owners across the UK depend on this system to fulfil sales and ensure the smooth running of their businesses. If your EPOS or card machine is connected to your landline phone line, it may be impacted by the PSTN switch off.

Some fire and rescue services also have payment systems for food and other services.

Whether or not your payment system continues to work after the switch off depends on whether it is connected to traditional PSTN lines or whether it uses a digital phone system.

Suggested actions:

Audit your payment system. Understand:
- How it works
- How it can be upgraded or replaced

Speak to your provider if you are unsure.

Consider alerting partners and business representatives. If you attend local business forums or similar, you may wish to raise awareness of the PSTN migration and its effect on payment systems to private-sector partners and business groups.

Remote monitoring and telemetry devices

Telemetry systems sense, collect and measure data from remote devices. Data collected is then transmitted from remote devices to a central control point, which allows the remote systems to be controlled.

Any telemetry equipment which relies on the PSTN for the transmission of data will no longer function correctly after the switch off and you will therefore need an alternative.

Suggested actions:

Audit your estate for telemetry systems. Understand:
- How many telemetry devices you have
- Where they are situated
- Whether they are connected to the PSTN
Identify and speak to your provider. If you need the device to operate 24/7, including during any power outages, you will need to ensure that they have their own battery and network backup. The best way for you to check this is to call your device provider and speak with them directly.
Engage with your provider to upgrade or procure replacement systems. It may be the case that existing systems can be adapted or upgraded so they continue to function after the switch off. If not, digital replacement equipment should be put in place before the switch off to ensure non-disruption of services. The best way to do this is to speak directly with your provider.