Compliance Attestation: 14 working days to go

Compliance Attestation21 March 2013:  Just 14 working days before telcos must file their first TCP Code Compliance Attestation.  If you think you’re now fully compliant with TCP Code requirements, why not complete your Customer Information Compliance Statement right now, so you can transfer the info onto the Comms Compliance website easily by the end of the month?

If you don’t think you’re TCP Code compliant …

What if you don’t already comply with the TCP Code?

Assuming that you have just a little bit of tidy up work left to do, keep progressing your compliance effort.  You’ve done well.

But if there are major gaps in your TCP Code compliance, you urgently need a strategy for dealing with ‘Compliance Attestation Day’.  You are already at significant risk of not being ready in time, so you must plan for that possibility.

If you know you won’t make the deadline, it’s time to start planning for a Compliance Achievement Plan (CAP):

9.5          Compliance Achievement Plans

If a Supplier is unable to submit to the CC a Customer Information Compliance Statement, a Compliance Attestation or a Statement of Independent Assessment (if required) at the times required by this chapter 9, the Supplier must submit to the CC a Compliance Achievement Plan detailing how and when actions will be taken to comply with the relevant Code requirement.

9.5.1      A Supplier must take the following actions to enable this outcome:

(a)          Inability to provide statements to the CC: if a Supplier cannot provide the Customer Information Compliance Statement, Compliance Attestation or Statement of Independent Assessment (if required) to the CC in the timeframe required in clause 9.4, provide a Compliance Achievement Plan to the CC (with contents and in a form acceptable to the CC) identifying the Code provision with which the Supplier does not comply and detailing the actions to be taken to become compliant and the expected timeframe for completion of those actions;

(b)          Monitoring and Reporting on Compliance Achievement Plan: if the Supplier provides a Compliance Achievement Plan to the CC pursuant to clause 9.5.1(a), monitor progress and report regularly on its progress under the Compliance Achievement Plan to the CC.

About Peter Moon

A telco lawyer with a truckload of experience
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