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Regulation

Omlets v Omlettes

Peter Farmer

2nd July 2026

We all know the saying: “you’ve got to break eggs to make an omlet(te).

Those who know me know that I have a general suspicion of Americana, but, I will give them this one. 

A few years ago, our friends across the Pond (ok, in my case, our friends due south) were fed up with SMS spam. The amount of scrotitude was just too much; the politicians knew they had to act. 

The Campaign Registry was born, and overnight, every scrote on the planet with crappy A2P SMS traffic was looking for a home. I remember it well. Our sales team at the time thought it was Christmas with the number of enquiries they had for a truck load of SMS. Only every single inquiry failed at the KYC stage, with a level of prejudice in the rejection that Simwood ultimately did a (temporary) stop-sell on SMS to the USA. 

The dodgy A2P SMS mosquito was thwacked. 

The market dynamics between the UK, and various EU member states are different. What works in the US cannot immediately be copied and pasted across. But, in SMS, the USA broke some eggs and made an omelet. With STIR/SHAKEN and voice, there was a similar political resolve to the SMS in the USA, but as we have [talked about before], application of the metaphor is perhaps that the broken eggs were scrambled, rather than used for a French delicacy.

That said, the volume of obviously scrotey traffic looking for a home is increasing – the volume of inquiries for “CC traffic” needing a home has risen, just like SMS did. Something about the USA market is working in relation to bad actors’ telephony. 

In the UK, there is a regulatory construct (actually, for the most part, non-binding guidance of questionable ability for Ofcom to use in an enforcement case). This is akin to the teacher asking the class prefects to keep order. For the most part, we see the adults in the industry doing that. Through information sharing, and co-operation, whack-a-scrote is a game being played by many. But that approach leaves the class clowns. 

Our own internal monitoring, as well as conversations at conferences, is beginning to tell us a story about who the clowns are. Some are obvious, some are foxes in the henhouses. As to their motives, be it ineptitude or greed, time will tell, but their existence in their current state leaves a vector for criminals to defraud our grandparents. 

The world has moved on – the argument that KYC is a friction that disincentivises sales is the purview of the Dinosaur. Here in Canada, I signed up for (and provisioned and had tested) the Rogers LEO satellite trial for SMS, which required a government-issued ID, during a hockey intermission. That’s less than eighteen minutes – the clock started from seeing their intermission commercial, to having it live. 

Some of our UK customers already embed ID-based KYC in their order journeys. I’ve trialled some, and it is no more intrusive than Verified by Visa popping up during your Amazon checkout. As to whether that lever is what Ofcom pulls, or whether the French model of suballocation is adopted, or the Norwegian approach to the international gateway is used – or all of the above – the UK increasingly needs to break some eggs to deal with the issue of scams. 

Of course, my call to action requires a regulator that cares more about our grandparents losing their life savings than a 17-year old seeing boobies on the internet, but I think it is increasingly time for the UK to make an omelette. Some of that may come from the proposed (if enacted) A2P rules, but that still leaves voice – and that’s a very significant part of the jigsaw that requires addressing. 

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