ANACOM recommendation on the collection of invoices on paper or other support

ANACOM today issued a recommendation to telecommunications operators not to charge any amount for the provision of non-detailed or minimally detailed invoices to their subscribers, whether on paper or any other support.

The origin of this recommendation by ANACOM are consumer complaints and news reporting that MEO intends to charge as of April for sending paper invoices to mobile voice customers and fixed and mobile Internet packages.

ANACOM also found that at least NOS and NOWO provide, in the contracts they use and in the disclosure they make of the conditions for offering their services, that sending a paper invoice by post implies an additional charge for their subscribers. .

These operators are thus making the sending of paper invoices subject to payment by their customers, which appears to be particularly burdensome for the most vulnerable sections of the population, namely the elderly, lower-income consumers and citizens with low schooling and digital literacy rates.

In accordance with the legislation in force, customers have the right to receive invoices for the services provided to them, and invoices that are not detailed or with the minimum level of detail set by ANACOM must be made available free of charge. This results from the Essential Public Services Act, the Electronic Communications Act and the Act on the processing of personal data and the protection of privacy in the electronic communications sector.

Furthermore, the issuance and delivery of the original invoice to the customer are obligations of the service provider and, as this is a tax obligation, ANACOM does not consider it legitimate for operators to pass on the charges they have to fulfill that obligation.

ANACOM's concerns in this matter are also shared by the Directorate-General for Consumers, DECO and the General Union of Consumers, which forwarded their positions on this situation to ANACOM.

On the part of the Directorate-General for Consumers, an express request was made to ANACOM so that, under the terms of article 47 of the Framework Law on Regulatory Entities, Law no. recommendation to operators that no amount can be charged for issuing a simple paper invoice and to adopt measures following complaints they have already received on this issue in order to prevent violation of the right to information/free paper billing.