I think it’s time to consider revisiting the CRTC’s Wireless Code. Indeed, it is past time to have such a review.
The Wireless Code is a mandatory code of conduct setting out rights for consumers of retail mobile wireless voice and data services, and defining obligations for providers of such services.
For more than a dozen years, the Wireless Code has served as the CRTC’s primary consumer‑protection framework for mobile services. However, it was created in a different era — before unlimited plans were common, before international roaming plans were widely available, before 5G, before eSIMs, before device financing innovations became the norm, and before wireless competition intensified across nearly every region of the country. Yet despite the pace of change in the marketplace, the Code itself has barely evolved, having last been tweaked nearly 9 years ago.
That wouldn’t be a problem if the Code were still aligned with how Canadians actually buy and use wireless services. But increasingly, it isn’t.
There were a number of populist-driven consumer measures ordered by Parliament in the 2024 Budget, as I described in a post last month. That legislation gave rise to a “trilogy” of CRTC Notices of Consultation: 2024-293 (Enhancing customer notification); 2024-294 (Removing barriers to switching plans); and, 2024-295 (Enhancing self-service mechanisms).
We now have device financing structures that didn’t exist when the Code was drafted, developed to provide relief from high monthly payments driven by regulated 24-month limit to amortize the cost of devices selling for thousands of dollars. We have multi‑line family plans, data‑sharing pools, and promotional pricing models that don’t map neatly onto the Code’s original assumptions. We have eSIM‑based switching that should make mobility easier, but is often slowed by legacy processes. We have a marketplace where competition is driving prices down, but the regulatory framework hasn’t kept pace with how consumers interact with their service providers.
At the same time, the CRTC’s own processes have slowed to the point where even minor clarifications can take months or years. As I’ve written before, regulatory delay has become a structural issue. When the regulator takes years to update rules that govern a sector evolving in real time, the result is predictable: uncertainty for carriers, confusion for consumers, and a framework that gradually loses relevance.
The Wireless Code is showing its age. Complaints to the CCTS increasingly involve issues the Code never contemplated — device financing disputes, promotional plan expiries, eSIM transfers, the complexities of multi‑line accounts. These are becoming the mainstream of today’s wireless market.
A holistic review is overdue.
A modern Wireless Code should reflect how Canadians actually use and shop for wireless services today, not how they used them in 2013. It should provide clarity for consumers and predictability for services providers. And, it should be developed through a process that is timely, evidence‑based, and focused on outcomes.
This isn’t about adding or deleting rules. It may mean simplifying or clarifying existing ones. But the starting point has to be a recognition that the marketplace has changed — dramatically — and the Code has not.
The CRTC needs to ensure its flagship consumer framework remains fit for purpose. That requires a full review of the Wireless Code, grounded in data, informed by actual consumer behaviour, and conducted with a sense of urgency that has been missing.
Canada’s wireless market has evolved. The rules governing it should too.