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October 21, 2019
The PSA explains that app stores previously had the benefit of an exemption from paragraph 7.2 of the Notice of Specified Service Charges and Durations of Calls (the requirement to send subscription spend reminders monthly or once a threshold of £20.45 in a month was met). The regulatory changes, as a result of the subscriptions review, meant that there was no longer a requirement to send spend reminders, and paragraph 7.2 was subsequently removed from that notice.
As a result, the PSA has made consequential amendments to the App Store Exemption Notice, removing reference to both the Notice of Specified Service Charges and Durations of Calls and to subscription spend reminders as these are now redundant.
Given the need for these amendments, the PSA has taken the opportunity to update and simplify the App Store Exemption Notice, removing extraneous and out-dated information about the app store pilot and other provisions regarding a grace period for the implementation of Children’s Service Caps, which expired in 2016.
By way of reminder, the app store pilot was conducted to test whether Code outcomes could still be met if app stores that enable operator billing were able to apply for permission for their Level 2 clients to operate without the need to register with the PSA (paragraph 3.4.1 of the Code), providing the PSA is satisfied that the participating app store has suitable controls in place so that the outcomes and expectations of the Code are met by other means. Following completion of the pilot, this exemption was made permanent in 2015. To read the PSA’s announcement in full, click here.