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Telecom - Staff Letter addressed to Philippe Gauvin (Bell Canada)

Gatineau, 26 November 2025

References: 1011-NOC2016-0293, 1011-NOC2019-0309

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19, 160 Elgin Street
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Subject: Wireless Code Compliance – Apparent non-compliance of Bell’s device financing practices – Request for Information

Dear Philippe Gauvin,

This is further to the letter from Scott Hutton, Vice-President, Consumer, Analytics and Strategy, dated 26 November 2025, regarding a new Bell Mobility (Bell) offering that allows customers to rent a device for the duration of their commitment and then pay off the remaining balance over 12 months, as detailed on Bell’s website.

In order that we may assess whether this practice is compliant with the consumer protections in the Wireless Code, please answer the questions outlined in Appendix 1 to this letter by no later than 8 December 2025.

Confidentiality information

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin 2010-961, parties may designate certain information as confidential.

A party designating information as confidential must provide a detailed explanation of why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure.

Furthermore, a party designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

A copy of this letter and of the answers to the appended questions will be available on the CRTC’s website and on the record of any other relevant proceeding the CRTC may launch.

If you have any questions, please contact Leah Paolini, Senior Policy Analyst, at Leah.Paolini@crtc.gc.ca.

Regards,

Original signed by

Guillaume Leclerc for Nanao Kachi
Director, Social and Consumer Policy

c.c.: Scott Hutton, Vice-President, Consumer, Analytics and Strategy, CRTC, scott.hutton@crtc.gc.ca
Leah Paolini, Senior Policy Analyst, Social and Consumer Policy, CRTC, leah.paolini@crtc.gc.ca

Appendix 1: Requests for information

Inextricable link

In Telecom Decision 2021-98, the CRTC clarified that device financing plans are subject to the Wireless Code where they are inextricably linked to the service plan. The CRTC further clarified that this occurs when: a) device financing plans are available only in conjunction with a service plan; b) the cancellation of the service plan will end the device financing plan and trigger the repayment; and c) the device financing plan is not portable if a customer wishes to use a different service provider.

The Frequently asked questions section of Bell’s Flex Option website notes that “[a]t any point within the additional 12 months, you may choose to end your service and either return the phone, pay the remaining balance in full, or continue with the scheduled device payments”. Please respond to the following:

  1. Confirm whether a customer could, during that additional 12-month period, cancel their service with Bell to switch to a different provider while continuing to pay the agreed-upon monthly amount until the device is paid off.
  2. Confirm whether a customer could, during that additional 12-month period, decide to modify or downgrade their service plan while staying with Bell and continuing to pay the agreed upon-monthly amount until the device is paid off.

Contracts and Critical Information Summaries

The Wireless Code (B.1. and C.1.) sets out that a service provider must provide a contract and critical information summary that, among other things, specifies key contract terms and conditions, explains how any early cancellation fees will be calculated, and sets out certain costs related to the purchase of devices. Please respond to the following:

  1. Explain how contracts and critical information summaries for customers opting for the Flex Option comply with the contract requirements set out in the Wireless Code during the initial commitment period. Provide examples.
  2. Explain how contracts and critical information summaries for customers who have opted for the Flex Option comply with the contract requirements set out in the Wireless Code during any period that: (i) follows the initial commitment period; and (ii) includes any period during which the customer is paying off the Deferred Amount in monthly device payments and/or any provisions related to the Flex Option apply. Provide examples.

Trial period

The Wireless Code (G.4.) requires that service providers offer a trial period of a minimum of 15 days to all customers and a minimum of 30 days for a customer who self-identifies as a person with a disability during which a customer may cancel their contract without any penalty or early cancellation fee if they have: a) used less than the specified permitted usage for any services not purchased on an unlimited basis; and b) returned any device in near-new condition, including original packaging.

The Frequently asked questions section of the Flex Option website notes that “[i]f you cancel your Service Agreement before 3 months have passed, you must pay back the Deferred Amount and keep your device”. Please respond to the following:

  1. Would a customer availing themselves of the trial period required by the Wireless Code be required to pay back the deferred amount and keep the device?
  2. Explain how this practice complies with the trial-period requirements in the Wireless Code.

Early cancellation fees

The Wireless Code (G.1. and G.2.) sets out that a service provider may not charge a customer any fee or penalty other than an early cancellation fee as calculated in the manner set out in section G.2.

The Frequently asked questions section of the Flex Option website notes that “[i]f you cancel your Service Agreement after 3 months have passed, you have 30 days from date of cancellation to return your device in ‘good working condition’. If you choose to keep your device, you will have to pay the Deferred Amount. This amount will be reduced when required by the Wireless Code”. Please respond to the following:

  1. Provide an example of how the “Deferred Amount ... will be reduced when required by the Wireless Code” and explain how this practice complies with the protections set out in the Wireless Code.

Plan extension

The Wireless Code (G.6.) allows a service provider to extend a contract with the same rates and terms and conditions on a month-to-month basis at the end of the commitment period to ensure that customers are not disconnected. Please respond to the following:

  1. For a customer opting for the Flex Option, describe what happens to the service plan they had subscribed to when the original commitment period ends.
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