Summary

  • Openreach ended national sales of new analogue lines on 5 September 2023 and plans to withdraw Wholesale Line Rental on 31 January 2027, a date BT Group moved from 31 December 2025 after an industry pause on non-voluntary migrations in December 2023 (Openreach, 2023; Comms Business, 17 May 2024).
  • Stop sell is triggered exchange by exchange once 75% of premises can obtain full fibre, with a year's notice to providers; Openreach says the rules had been activated in 1,041 exchanges covering 8.9 million premises by 19 August, about 46.4% of its full-fibre footprint (Openreach stop-sell notice; BT Wholesale tranche reference).
  • The protection regime is documented: Ofcom rules on power resilience and vulnerable customers, a provider charter signed in December 2023, a network operator charter, government supported-journeys guidance, and a non-voluntary migration checklist (Ofcom; PSTN Charter; Network Operator Charter; supported journeys; checklist).
  • The government's Telecare National Action Plan states that uninterrupted access for telecare devices is not a regulatory requirement, because telecare devices do not dial 999 (Telecare National Action Plan).
  • The quantified evidence of effect is produced by the operator executing the withdrawal: more than 1,000 telecare customers migrated in a pilot, more than 70,000 upgraded, over 4,000 trained engineers, and a last-resort service priced at £35 and £38.60 a month (Prove Telecare; closure safeguards).
  • Openreach separately estimated that about 1.5 million lines remained on copper, including roughly 350,000 business premises, and named payment terminals, lift alarms and security systems among the at-risk equipment (Openreach business notice).

The dispute worth reporting is not whether the copper network is closing. It is which control has dated, published evidence of working after an adverse event, and who bears the consequence when that evidence is missing.

The mechanism: what actually changes for an alarm

An analogue line is not merely an old way of carrying voice. It is powered from the exchange and it is engineered around a continuous circuit, which is why a pendant alarm or a lift line could historically assume that the dial tone would be there when the button was pressed. A digital service carries the call over customer premises equipment that depends on power inside the building, and the alarm itself has to be compatible with the new call path.

Ofcom's guidance requires providers to give consumers a minimum of one hour of power resilience in a power cut, free of charge where the landline is used to call the emergency services (Ofcom). The government's action plan assigns the compatibility duty to telecare service providers, which it says must test equipment for IP compatibility and replace, upgrade or reconfigure it as needed (Telecare National Action Plan).

The same document states the legal limit plainly: there is no regulatory requirement for communications providers to ensure uninterrupted access for telecare devices, because those devices do not dial 999. That sentence is the hinge of this story. Everything else in the protection regime is a commitment layered on top of a baseline that does not guarantee the service the affected person actually depends on.

The schedule on paper

Openreach stopped selling new analogue services nationally on 5 September 2023, saying more than 500 exchange areas covering about 4.6 million premises were already in the stop-sell phase, and describing a phased approach in which copper products were withdrawn first at exchange level and then nationally (Openreach, 2023). Stop sell is triggered when 75% of premises connected to an exchange can obtain ultrafast full fibre, and communications providers receive a year's notice; Openreach reported that by 19 August, stop-sell rules had been activated in 1,041 exchanges covering 8.9 million premises (Openreach stop-sell notice).

BT Wholesale's own reference document lists the tranche history from the early trials at Salisbury (1 December 2020) and Mildenhall (4 May 2021) through the tranches scheduled into 2026, alongside the national WLR stop sell of 5 September 2023 and the January 2027 withdrawal date (BT Wholesale).

The date has already moved once. Trade reporting in May 2024 recorded BT Group's confirmation that the migration deadline had been extended to January 2027 from 31 December 2025, following an industry-wide pause on non-voluntary migrations in December 2023, with an Openreach spokesperson saying the withdrawal of WLR products had been aligned to 31 January 2027 and acknowledging that more work was needed to mobilise the minority of non-engaged providers (Comms Business, 17 May 2024). A schedule that has slipped once is not a schedule that has been tested to completion.

The declared control layer

Read together, the control documents form a coherent structure. Ofcom requires providers to identify, protect and support vulnerable customers, expects clear published policies for their fair treatment, sets the one-hour power-resilience floor, and says it has monitored providers' switchover progress quarterly since 2019 (Ofcom).

The Public Switched Telephone Network charter, signed by major providers in December 2023, commits them not to undertake non-voluntary migrations until they are confident they are taking all possible steps to protect vulnerable people, and states that no telecare user will be migrated without the communications provider, the customer or the telecare company confirming that a compatible and functioning solution is in place. The same charter commits signatories to work beyond Ofcom's one-hour minimum where battery back-up is provided, to agree a shared definition of vulnerability with government and Ofcom, and to run additional checks on customers who had already been migrated non-voluntarily (PSTN Charter). A complementary network operator charter signed in March 2024 extends the voluntary arrangement to the operators of the network itself (Network Operator Charter).

Government guidance on supported journeys sets out who is in scope — users of telecare, social alarms and medical equipment, and landline-dependent customers at heightened risk of harmful outcomes — and ties provider conduct back to Ofcom's General Conditions of Entitlement (supported journeys). The non-voluntary migration checklist is the most operationally specific instrument: providers are to contact customers well in advance using at least two forms of communication and explicitly ask whether they are telecare users, seek data-sharing agreements with local authorities, check whether a line dials alarm receiving centre numbers, offer a free engineer visit where additional support is needed, and restore the telephone as a priority where a vulnerable customer complains that the line was disconnected or a telecare device failed after migration (checklist).

That last item deserves to be read precisely. Priority restoration is a remedy that begins with a complaint. It is triggered after somebody notices that the line is dead or that the alarm did not work — which is a different proposition from a control that detects the failure before it matters.

The evidence of effect, and who produces it

Against that paper structure sits a much smaller set of numbers, and all of them originate with the organisation executing the withdrawal. Openreach describes a Prove Telecare pilot in which engineers migrated more than a thousand customers using fixed-line telecare devices to digital voice services without disruption, supported by more than 4,000 specially trained engineers working with alarm receiving centres; incompatible devices are returned to copper and the customer's communications provider and telecare provider are informed (Prove Telecare). In a later notice on closure safeguards, the company says its telecare service has safely upgraded more than 70,000 customers with telecare devices, and sets out EVAc, a temporary last-resort phone service for customers not moved to a digital service, priced at £35 per month for WLR3 Basic and £38.60 for WLR Premium (closure safeguards).

Those figures describe migrations performed. They do not describe reachability verified. The material reviewed for this report contains no device-level post-migration test results, no power-cut test results for migrated alarms, no published rate at which devices were found to be incompatible, no count of telecare users whose devices were unknown to their provider, and no failure rate after migration.

Meanwhile the residual exposure is quantified in the operator's own business-facing appeal: around 1.5 million lines still on the old network, about 350,000 of them business premises, with payment terminals, lift alarms and security systems named among the services at risk, alongside rental increases for WLR basic and variants of 40% in July and a further 40% expected in October, taking charges to roughly double (Openreach business notice). Price is itself a migration instrument.

Three scenarios the regime does not fully cover

The first is the power cut that outlasts the battery. Ofcom's floor is one hour of resilience for a landline used to call the emergency services, and the charter commits providers to work beyond it where battery back-up is supplied (Ofcom; PSTN Charter). Neither instrument states how long a domestic telecare alarm must remain able to raise a call, because government has said uninterrupted telecare access is not a regulatory requirement (Telecare National Action Plan). The gap between one hour and an actual outage has no published owner.

The second is the unknown device. The checklist's identification tools are deliberately broad — ask the customer, share data with local authorities, look for calls to alarm receiving centre numbers — and its own framing implies that some devices will only be discovered afterwards, which is why it requires additional checks on customers already migrated and priority restoration when a failure is reported (checklist). Every one of those mechanisms is reactive or heuristic.

The third is equipment that is life-critical but not a domestic telecare pendant: lift lines, fire and security systems, payment terminals. Openreach names them as at risk (Openreach business notice), while the charters, the action plan and the supported-journeys guidance are framed around vulnerable consumers (PSTN Charter; Telecare National Action Plan; supported journeys). A building manager replacing a lift line is not the beneficiary of a telecare-specific commitment.

What would close the gap

Four items would convert a declared regime into a verifiable one, and each is observable rather than aspirational: device-level confirmation that a migrated alarm reached its receiving centre on a scheduled test; published results of power-cut testing on migrated alarms; counts that separate lines migrated from lines verified, including the number of devices discovered after migration; and disclosure of post-migration failure or complaint rates, including the volume of priority restorations actually performed under the checklist (checklist). Regulatory enforcement data against named providers would supply an independent check on the same questions (Ofcom).

None of this requires the schedule to change. It requires the evidence to be produced by someone with no stake in the migration count, and published before the copper is gone rather than after the first failure is reported.

Bounded consequence and residual uncertainty

The most likely outcome is not a mass failure. It is a long tail: a small number of devices in the wrong configuration, in the wrong power environment, on a line whose provider believed the migration was complete. Because exchange-level withdrawal is one-way — after WLR withdrawal there is no analogue service to fall back to — a silent failure is not corrected by restoring the old line; it has to be found and rebuilt.

The honest uncertainty is symmetric. Openreach's process may include verification steps that have simply not been published, and the pilot's reported result — more than a thousand migrations without disruption — is real evidence of something, produced under engineer supervision rather than at national scale. The government's position that telecare continuity is not a regulatory requirement is a statement about legal duty, not a claim that no harm can occur.

What cannot currently be established from the public record is the thing that matters most to a person wearing the pendant: that the alarm on their wall was tested, under adverse conditions, after their line changed.