Written evidence submitted by BT Group (CISDC0019)

Scottish Affairs Select Committee inquiry:

Connectivity in Scotland: Digital connectivity

Background

BT Group is the UK’s leading provider of fixed and mobile telecommunications and related secure digital products, solutions and services. We also provide managed telecommunications, security and network & IT infrastructure services to customers across 180 countries. BT Group consists of four customer-facing units: Consumer serves individuals and families in the UK; Business covers companies and public services in the UK; International serves multinational organisations headquartered outside the UK and internationally; Openreach is an independently governed, wholly owned subsidiary wholesaling fixed access infrastructure services to its customers - over 700 communications providers across the UK.

Our ambition is to become the UK’s most trusted connector of people, business and society, and to deliver on our purpose – connect for good.

We are the leading investor in the UK’s networks (FSTE 100’s biggest capex investor into UK infrastructure). We’ve invested £24.3bn in capex this decade and expect to invest around £20bn more before the decade is over.

As part of our commitment to Scotland, BT Group has been supporting some of the most remote communities as part of our work with the UK Government’s Shared Rural Network (SRN) and the Scottish Government’s 4G infill programme (S4GI). Via Openreach, BT Group is also delivering future-proofed digital infrastructure through the R100 contracts that will underpin economic growth and enhance the economic prospects of communities across Scotland for decades to come. Alongside our work on mobile and broadband connectivity, we are delivering transformational public sector services for people across Scotland via the SWAN Framework, under our contract with the Scottish Government.

Across BT Group, including BT, EE, and Openreach, we support 7,700 full time employees in Scotland. Our most recent Economic Impact Report, prepared by Hatch Urban Solutions, calculates that in 2023/2024, the total Gross Value Added (GVA) of our activity reached £1,310m in Scotland, including indirect and induced effects of BT Group’s activities and spending.

Our response

1) What are the main barriers to delivering full-fibre and gigabit-capable broadband in Scotland’s rural and island communities?

• How effective has the rollout of Project Gigabit been in Scotland?
• To what extent are UK Government initiatives coordinated with the Scottish Government’s R100 programme?
• What lessons can be learned from previous broadband rollout schemes, such as superfast broadband?

Openreach will be responding separately to the Committee to cover BT Group investment in full-fibre and gigabit-capable broadband.

2) What is the future outlook for 5G deployment in rural Scotland, and what lessons can be taken from the 4G rollout?

• What impact has the Electronic Communications Code had on mast hosting agreements and mobile infrastructure deployment in Scotland?
• What are the implications of landowner resistance or withdrawal from hosting mobile infrastructure in Scotland?

Network investment in Scotland

BT is the leading investor in the UK’s digital networks – and we are investing to help close the UK’s digital divides wherever they are to be found, including in rural Scotland. The positive outlook for 5G deployment in Scotland is underpinned by our ambition to extend a 5G connection anywhere in the UK by 2028. Work is already underway as we’ve significantly expanded the reach of our 5G network in recent months, delivering faster mobile speeds and greater capacity at peak times for our customers. Since January 2024, our 5G population coverage in Scotland has increased by almost 15% and now stands at more than 84% (geographic coverage is 24%). For 4G coverage, our network reaches more than 99% of the population and just under 80% of the geography.

We are also delivering the nation’s most ambitious rollout of 5G+, the most advanced mobile network, which will enable us to deliver 5G+ to 99% of the UK population by the end of March 2030 – four years ahead of other UK mobile operator’s stated projections. In Scotland, 5G+ on EE is already available in many major towns and cities, including Aberdeen, Edinburgh, Glasgow, and Dundee, with Greenock and Hamilton being the most recent additions.

In the meantime, we have extended 4G coverage to rural communities through the Shared Rural Network, a joint £1 billion investment programme between mobile operators and the UK Government. EE was the first mobile network operator to meet its commercial SRN coverage targets in June 2024, 6 months ahead of schedule. Our investment is enabling us to build an increasing number of masts which have expanded and strengthened our EE network in more than 493 rural communities across Scotland. This includes building 175 brand new mobile sites to deliver reliable connectivity to local communities in some of the most remote locations, as well as making our network live on an additional 51 sites as part of the Scottish Government’s S4GI programme – more than any other operator. [1]

From a planning perspective, barriers remain for delivering mobile infrastructure. These include:

• The planning guidance for mobile connectivity does not appropriately reflect the public interest, as well as local and national benefits offered by improved connectivity.
• The planning system is facing delays and poor outcomes due to various challenges, such as increasing demand, low retention rates and aging workforce.
• The processing of planning appeals is slow. This process currently takes between five to 12 months, even for minor developments, which can lengthen the time for building and activating sites to over two years.
• From a regulatory perspective, we believe that the limit for deploying monopoles without a full planning application should be increased from the current 15m to 20m. Monopoles are less intrusive than standard masts and offer similar coverage and capacity benefits.

The need for improved mobile connectivity is not restricted to rural Scotland. We see increased demand on our network in Scotland’s towns and cities, particularly when there is a major event taking place. We are installing 4G and 5G small cells to add extra capacity to our network at peak times in busy areas and tourist hotspots – for example around the Castle and Royal Terrace Gardens in Edinburgh, at Argyle Station in Glasgow and the Overgate Shopping Centre in Dundee.

Customers expect access to high quality voice and reliable data services, whenever they need them and wherever they are – including when they are travelling on our road and rail networks.

Earlier this year, we set out the case for targeted Government action to work with industry to deliver mobile networks fit for the future, asking the independent analyst-firm Assembly to model the economic and/ or social benefits to the UK that could be delivered by addressing low mobile network quality through different investment options.[2] This research indicated that delivering a highly resilient, nationwide high-capacity network could unlock up to £230bn in economic benefits by 2035, as well as a broad range of social and environmental benefits.

The report recommended a new Mobile Markets Review, recognising how the Fixed Telecoms Infrastructure Review carried out by DSIT had previously helped kickstart investment in fill fibre networks. Such a review would provide the opportunity to look to help operators deliver greater coverage and capacity in a cost-effective manner through releasing more spectrum, as well as reducing deployment barriers – including the planning issues set out above.

As a result of our own on-going investment, EE is proud to have recently been recognised by Umlaut Connect for the eleventh consecutive year as the UK’s best mobile network following a robust independent benchmarking process.[3]

Impact of Electronic Communications Code

Overall, the Code is working well in Scotland. The 2022 Product Security and Telecommunications Infrastructure (PSTI) Act made important reforms to Electronic Communications Code (ECC or the ‘Code’), enhancing the rights of network operators to deploy mobile network infrastructure It built on the significant to the Code brought in by the Digital Economy Act 2017.

The Government’s clear decision not to fundamentally change the Code nor to revise the approach, established by the 2017 Act, to the valuation of land for the purposes of hosting telecoms infrastructure was particularly welcome. The current regime has rightly brought telecoms more closely into line with rents paid by utility providers such as water and energy and on the whole, the market in Scotland has adapted well. The 2022 PSTI Act reforms have addressed a number of barriers to mobile deployment, including:

• Removing – through the introduction of interim arrangements for renewal negotiations – some of the incentives for landowners and their agents to delay negotiating new agreements.
• Addressing problems in agreeing new Code terms for leases where land has previously been occupied under different legislation and the Landlord and Tenant Act 1954
• Enabling terms to be reached more quickly where land is occupied under an expired “old” Code agreement (i.e. pre-2017).
• Ensuring that upgrades to equipment e.g. to deploy 5G on an existing 4G site can be made more easily

The ECC reforms have supported swifter rollout of mobile coverage, particularly in rural areas. Since its introduction, EE has built hundreds new masts across the countryside including in Scotland, delivering vital 4G mobile coverage to hundreds of communities for the first time as well as upgrading hundreds of existing 4G sites to 5G since May 2019. An effective Code has also been critical in delivering the objectives of the Shared Rural Network programme.

A small number of the PSTI Act provisions have yet to be implemented. Although they will not affect our deployment in Scotland (they focus on alignment with legislation concerning England, Wales and Northern Ireland) we strongly encourage the UK Government implement the remaining measures of the PSTI Act as quickly as possible to provide greater consistency across the UK as a whole.

We have not observed any widespread or significant landlord resistance or withdrawal from hosting mobile infrastructure in Scotland. Indeed, Scotland has proved less contentious than in England and Wales in our ability to both secure renewal agreements (due to the existence of tacit relocation)[4] for our existing infrastructure and also to acquire new sites. We work hard to reach consensual agreements with landlords in order to avoid asking the courts to impose Code-based rents, as evidenced, for example, by the fact that 99% of our renewal negotiations with landlords have been agreed consensually, without the need for hearings. In the very small number of instances that litigation has been required, the Scottish tribunals system has consistently been efficient and tended to progress matters faster than in England and Wales. For many years, its application of Code principles has been clear and consistent, which has greatly assisted in settling the market.

We did recognise the challenges that the reforms changes created for some of existing landlords who have historically received high rents (though fair lower than those reported by the media). We put in place a number of measures to mitigate this, including phasing rent reductions and providing upfront lump-sum payments in some cases.

More generally, we are monitoring what lease aggregators (entities who intervene in existing relationships between landowners and Code operators), are doing in Scotland. Code litigation in connection with the renewal of Code agreements in England and Wales is dominated by cases involving a single lease aggregator.

3) What are the knock-on impacts to transitioning to digital services for those in Scotland’s rural communities? This could include but is not limited to: the phase-out of Radio Teleswitch Service (RTS), the move away from analogue landlines and moving towards an online-only television service.

• What support is there for affected households, and is it sufficient?

Digital Voice

The digital landline switchover – being made by all UK communication providers – is a critical upgrade to the UK’s telecommunications infrastructure. The current PSTN (Public Switched Telephone Network) technology is rapidly approaching the end of its serviceable life, is increasingly prone to faults and becoming harder to maintain. Retiring the network will enable the provision of more resilient, future-proofed landline services across the UK. It will also provide significant benefits, improving digital inclusion (enabling more people to access fibre broadband) and reduce scam calls.[5] As of the end of November 2025, BT had transferred 280,000 (73%) of its landline customers in Scotland to Digital Voice with a further 109k (27%) remaining.

The switchover is straightforward for most customers; however, those who rely more heavily on their landline require additional support. That is why BT, along with other communication providers, has worked closely with the UK Government and Ofcom to implement strong protections for customers to ensure the switchover can happen as safely and smoothly has possible. This includes signing up to the Government’s PSTN Charter of Commitments[6] and PSTN non-voluntary migration checklist[7], as well as identifying and defining those customers requiring supported migration journeys through the transition.

BT’s migration programme has been developed to ensure there is appropriate support in place for all customer needs. This includes:

• Providing resilient solutions to keep customers connected during a power outage: this includes a batter back-up unit (BBU) – free of charge to those who require supported journeys. The BBU includes a hibernation function that rations the battery’s life to extend well beyond the regulatory requirement to provide at least one hour of back-up time. Eligible customers can also receive a free hybrid phone, which automatically fails over the mobile network in the event of a power cut and has a built-in battery.  Providing a dedicated service for customers who only use landlines (such as those who cannot access or use broadband), known as Pre-Digital Phoneline (PDPL). This solution converts a signal analogue into a digital one in – it means eligible customers can continue to use their landline as they do today while still enabling the withdrawal of the PSTN.
• For customers who use telecare devices (such as care alarms and pendants) we have developed Prove Telecare. This service will involve specially trained Openreach engineers work directly with alarm receiving centres to confirm households using telecare devices, and only complete migrations when devices are compatible.[8]
• BT has worked with local authorities across Scotland, signing Data-Sharing Agreements (DSA) to help us identify telecare users in their area.
• BT has also supported the Digital Voice rollout with comprehensive awareness raising. Over the past couple of years, we have carried out an extensive awareness campaign with public information sessions in communities in every local authority of Scotland – provided by BT and in partnership with community organisations - to promote the measures we have put in place during the switch over. We also launched the National Telecare Campaign, alongside DSIT and VMO2, encourage telecare users and their support networks to let their Communications Provider know if they have a telecare device.

Supporting the transition to digital services through investment in networks

With the increasing unpredictability of climate change, extreme weather and an uneasy geopolitical landscape, the resilience of our networks will always be a key priority for us.  We fully recognise the importance of maintaining reliable communication links during the transition to digital services. Our work to ensure that all communities, particularly those in rural and remote areas, have access to robust and resilient communication infrastructure includes:

• Over the next four years, we will more than triple the number of backup power generators at our mobile sites across the UK – delivering additional resiliency during storms and power outages for over 90% of the population.
• We already have extensive resilience in our core network, with generators that provide seven-day backup in the event that power goes down.

• Wherever possible, we also design our mobile masts to provide overlapping coverage to lessen the impact on connectivity in the event of localised power outages during bad weather.
• Our first self-powered mobile site has been installed in the UK (powered by wind and solar energy), and we continue to explore options for building more of these in the future. These self-powered sites provide additional mobile resilience, especially in areas where it’s difficult to provide overlapping coverage from multiple masts.
• At the same time, we’re continuing to work closely with the distribution network operators in the power sector to improve coordination and information sharing in the event of any future storms and subsequent power outages.
• In the UK, 999 calls to emergency services automatically connect via any available mobile network in the event a person does not have signal with their usual provider.

A more detailed overview of how we are working to improve resilience across the network is available below.

• Emergency Response Team (ERT): BT has a dedicated national and regional Civil Resilience team and Emergency Response Team that works 24/7 to respond to major civil emergencies, including those caused by extreme weather events like storms and flooding.
• Mobile Fleet: The ERT uses a fleet of specialist emergency response vehicles equipped with generators, lighting, satellite communications, and command and control capabilities. These can be deployed to incident sites to provide temporary power and communications until normal service is restored.
• Infrastructure Resilience: Traditional telephone exchanges running on the PSTN (Public Switched Telephone Network) generally have significant standby power (at least 24 hours of battery backup, some with generators). For the newer full-fibre (FTTP) network, Openreach provides resilient Uninterruptible Power Supplies (UPS) at the street cabinets, and some sites have longer-lasting power solutions.
• Collaboration: BT works closely with Category 1 and 2 responders, local authorities, and power companies (like Scottish and Southern Electricity Networks - SSEN) to coordinate effective response plans and share information during power disruptions.
• Proactive Maintenance: Openreach has a large engineering force that works in all weather conditions to replace damaged infrastructure such as the hundreds of poles damaged by bad weather each year to restore service as quickly as possible. 

Moving towards an online only television service

• We believe the UK needs to start preparing now for the inevitable transition away from terrestrial TV broadcasting on to IPTV. There is an opportunity here to help get older, tech-averse households connected to the internet (through IPTV) and in turn enable the digitisation of more public services.
• We expect that this move will stimulate demand for initiatives to increase digital inclusion and raise levels of confidence in using technology, such as BT’s partnership with the charity AbilityNet, now in its third year of supporting sessions for the elderly and disabled in communities across Scotland.[9]

4) What role could satellite technologies, or other alternative solutions play in improving connectivity in Scotland’s remote areas?

• What are the barriers to adoption of these technologies and how might they be overcome?

We recognise that the installation of satellite services is likely to deliver a transformative impact on the communities and businesses, connecting sites that are in remote and otherwise challenging locations.

This is why, in November 2025, we became the first operator in the UK and one of the first globally to announce a landmark agreement with Starlink. This will see BT Group offer ultrafast, low-latency satellite connectivity to customers in rural and remote areas where traditional fixed-line infrastructure is economically unviable or geographically challenging to build. The agreement marks a significant milestone in making high-speed internet connectivity widely accessible within the hardest to reach parts of the UK – with the service expected to be available to customers in the latter half of 2026.

During the recent outage on the island of Tiree as a result of damage to the subsea cable, BT installed Starlink terminals on its mobile masts to provide connectivity for islanders.

For island communities, we are working on a new resilience solution which will use satellite terminals to provide a back-up service in the event of a terrestrial transmission failure.

December 2025

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