ANACOM Recommendation on the application of charges for the issue of invoices in paper or another medium

ANACOM recommends telecom operators not to charge any amount for the issue of non-itemized invoices or invoices with a minimal level of detail, either in paper or another medium. ANACOM’s recommendation stems from complaints submitted by consumers and news reports that MEO intends to charge as from April the issue of paper invoices to mobile voice customers as well as customers of fixed and mobile Internet bundles. 

ANACOM also found out that at least NOS and NOWO set out in contracts they use and disclosures of their service offering conditions, that the issue of paper invoices, sent by mail, implies an additional burden on subscribers.

These operators thus make the submission of paper invoices dependant on the payment by customers of a specific amount, which is deemed to be particularly serious for the most vulnerable sections of the population, such as the elderly, consumers with a lower income and citizens with low levels of schooling and digital literacy.

According to legislation in force, customers are entitled to receive invoices for services provided, and non-itemized invoices or invoices with a minimal level of detail established by ANACOM are required to be provided free of charge. This follows from the law on Essential Public Services, the Electronic Communications Law and the law on the processing of personal data and the protection of privacy in the electronic communications sector.

Moreover, the issue and delivery of the original invoice to the customer are duties the service provider must observe, and as this is an obligation of a tax nature, ANACOM believes that it is not legitimate for operators to pass on their customers the charge they are required to bear to meet that obligation.

ANACOM’s concerns on this matter are also shared by the Consumer General Directorate, DECO and the General Consumer Union, who submitted to ANACOM their positions on this situation.

ANACOM is closely monitoring the developments on this subject and will not stop exercising all its legal powers.