After initially ruling that there was no requirement for telecommunication providers to provide paper billing earlier this year, the Canadian Radio-television and Telecommunications Commission (CRTC) is now reviewing 79 public submissions in response to its public consultation.

In March, the CRTC ruled against a complaint brought against TELUS because its Koodo brand switched all customers to electronic billing. The complaint was brought by the Public Interest Advisory Commission (PIAC) and the National Pensioners Federation (NPF). The CRTC said its rules did not require carriers to provide paper bills, except for certain provisions in which customers with disabilities required alternative formats. However, the CRTC also acknowledged receiving numerous complaints from customers, including seniors who reported difficulty in paying bills online, and allowed for a public call for comments.

A review of the 79 submissions shows a sharp contrast between the position of the service providers and consumer groups.

Telecom service providers argued that there was no need for the CRTC to intervene, as most major providers allow consumers to elect to continue to receive paper invoices at no additional cost. Bell Canada’s submission hedged slightly, noting that if the CRTC thought regulation was necessary to require paper invoices “it should only apply to vulnerable Canadians.”

The Consumers Council of Canada submission was drawn from responses to a questionnaire given to its Public Interest Network. PIN members “clearly and overwhelmingly indicate that anyone who wants a paper bill should get one. They may be divided about their preferred billing method, but they are unified in the belief that consumers should have a choice.” The submission also noted there are many reasons to prefer paper billing that aren’t listed in the exempt categories noted by the CRTC in its initial ruling.

PIAC’s submission also opined that consumers should have the right to receive paper bills if they choose, and only switch to paperless billing voluntarily, not as an imposed choice from which they may opt out.

The British Columbia government submission also noted that consumers should be available on customer request at no charge, customers should be able to switch billing preferences at any time, and that information about billing practices should be provided anywhere a wireless service may be purchased.