Page 195 - ITU-T Focus Group Digital Financial Services – Technology, innovation and competition

ITU-T Focus Group Digital Financial Services
Technology, Innovation and Competition

5.2.3 Access to USSD Short Codes

The ‘short code’ access code numbers used to access USSD sessions may be assigned by the MNO at their
discretion, although in some markets a regulator may do so. This issue and the competition-related impact
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relating to short codes is outlined in more detail in Section 7.

5.2.4 Length of A USSD Session

5.2.4.1 Competition Aspects
The length of a USSD session may be restricted by the MNO for third party providers, such that there is not
enough time for customers to input long account numbers when prompted. Similarly, MNOs may restrict the
time allowed for the input or for the customer to provide input to advance to the next tree on the menu.
MNOs may cite the so-called ‘opportunity cost’ inherent in providing USSD to third parties, since they argue
that the GSM system design may mean that use of USSD (signaling) channel may block revenue-generating
incoming and outgoing voice calls for the duration of the live USSD session. Further, they believe that a
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commercially and technically viable arrangement would allow for a price and length/stages of sessions that
are commensurate since increased time increases the use of the USSD resource.
MNOs have discouraged sessions lengths being increased where, as in India, it is implemented in tandem with
a cap on the pricing per session. While not necessarily a competition-related example, recent regulations in
India may illustrate the tension between length of USSD sessions and profitability for MNOs: in November 2016,
following a short consultation process on its quality of service regulations, the Telecom Regulatory Authority
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of India (TRAI) increased the maximum number of USSD menu stages from five to eight per USSD session as it
found the menu stages – and thus the total length of the USSD session - too short for users to properly input
long account numbers Simultaneously, TRAI cut the permitted cost of a USSD session by two thirds.
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5.2.4.2 Country example

Uganda

In Uganda, one of the biggest MNOs charges USSD sessions in increments of 20 seconds while another MNO
charges in increments of 100 seconds. The length, duration, quality and wholesale charges of USSD sessions
used in DFS are the subject of an ongoing investigation into anti-competitive behavior by the UCC. 104

5.2.5 USSD menu trees

5.2.5.1 Overview
Current ceilings for the number of stages allowed in a USSD session pose challenges in creating customer
friendly menus for USSD-based access to DFS. These may result in input errors or time delays and may

100 See on USSD policy, TRAI (2016a) ibid
101 See for example the responses the TRAI received when canvassing local MNOs on use of USSD. The MNOs indicated that any
move to increase the number of stages in a USSD menu would put a load on their signaling infrastructure and, therefore, that
there should be a commensurate increase in the ceiling tariff for USSD session from the present level if the number of menus
available were increased. Other MNOs were agreeable to increasing the number of stages provided such USSD sessions were
restricted to transactions related to financial inclusion only and not for any other additional financial services such a mobile
banking. TRAI (2016a) ibid
102 First Post (2016) TRAI Lowers Tariff For USSD Based Mobile Baking To A Maximum Of 50 Paise Per Transaction, available at
https:// goo. gl/ zF9ggZ
103 TRAI (2016b) Information Note to the Press (Press release No 110/2016), available at https:// goo. gl/ V1qZJ0; and TRAI (2016c)
The Mobile Banking (Quality Of Service) (Second Amendment) Regulations, 2016, available at https:// goo. gl/ XwPxzn
104 UCC (2016) ibid

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