1. Review of the short codes provision of the Uganda National
numbering plan
Consultation Document

2. CONSULTATION PROCESS
Background
During the 2003 review of the Uganda National Numbering Plan, it was decided that
operators independently identify and administer their own short codes for provision of
customer and value added services (VAS) on their networks.
However, in the first quarter of 2005, it was observed that the operators had started to
issue the shortened numbers to third parties in place of subscriber numbers in a
manner of great concern to Uganda Communications Commission (UCC).
Subsequently, in July 2006, after consultation with stakeholders and taking into account
experiences elsewhere, UCC took back the administration of the short code numbering
resource to realize the following objectives:
 To promote growth and development of the communications sector in Uganda
 To promote efficient utilization of the number resource in Uganda
 To promote fair competition in the sector
 To improve existing framework for the administration of the numbering
resource to ensure transparency and efficient management
 To ensure that future developments are provided for through reservation of
numbers
The provision was further clarified in 2007 to facilitate implementation of the same.
However, developments since then have resulted in a need to review the Provision to
enable the realization of the above stated objectives.
UCC under this consultation document invites comments and proposals on various
issues currently pertaining to the allocation and usage of short codes under the Uganda
National Numbering Plan.
Uganda Communications Commission Consultation Document, Jan 2012 Page 2

3. Making a submission
Only written submissions (Electronic/hard copy) will be considered.
The close of submissions to this paper is 5.00 pm on Friday 10th February 2012.
Submissions received after the above indicated date may not be considered in making
the amendment to the short code provision of the Uganda National Numbering Plan.
Submissions may be sent to:
The Executive Director
Uganda Communications Commission,
UCC House
Plot 42-44 Spring Road,
Bugolobi - Kampala
Or by email to:
research@ucc.co.ug
ucc@ucc.co.ug
Confidentiality: UCC prefers to receive submissions which are not claimed to be
confidential. However, the Commission will accept that a contributor may sometimes
wish to provide information in confidence.
In these circumstances, contributors are asked to identify the material over which
confidentiality is claimed and provide a written explanation for confidentiality claims.
Automatically generated confidentiality statements in emails DO NOT suffice for this purpose.
UCC will consider each claim for confidentiality on a case by case basis. If the UCC
accepts a confidentiality claim, it will not publish the confidential information unless
required to do so by law.
Uganda Communications Commission Consultation Document, Jan 2012 Page 3

4. Definitions
Allocation – Permitting the use of the respective code(s)
Application Provider – Creates and manages information and products to the
consumers through computer based or electronic services over service networks of
Public service providers.
Global System for Mobile Communication (GSM) – This is the most widely used
mobile communication telephony technology in the world.
Network Operator – A Public Service provider who provides mobile telephony services
to consumers
Short Message Service (SMS) – This is a messaging functionality that enables exchange
of text messages between mobile phones through a store and forward mechanism on a
mobile telephony network.
Unstructured Supplementary Service Data (USSD) – This is a connection oriented
service that enables real time messaging between the mobile phone and application
programs on a mobile network.
Uganda Communications Commission Consultation Document, Jan 2012 Page 4

5. ACRONYMNS
GSM Global System for Mobile Communication
USSD Unstructured Supplementary Services Data
VAS Value Added Services
SMS Short Message Service
MMS Multimedia Message Service
MTN Mobile Telecommunications Network
UCC Uganda Communications Commission
UTL Uganda Telecom Limited
Uganda Communications Commission Consultation Document, Jan 2012 Page 5

6. 1 INTRODUCTION
The Uganda Communications Commission is mandated under section 4(g) of the
Uganda Communications Act, Cap 106 Laws of Uganda “to establish, amend and
enforce a national numbering plan and to perform block number allocations”.
In 2007, after consultations with the existing telephony operators, Uganda
Communications Commission (UCC) reviewed the structure of short codes in
Uganda, their use as well as their allocation. Accordingly, the current short code
provision was set up as fully defined in the current UCC Numbering plan Guidelines.
Major changes made to the provision were as follows:
(i) There shall be 3 digit codes of the form 1XX and 4 digit short codes in the
range 6XXX – 8XXX for X=0-9.
(ii) The 3-digit shortened numbers should be reserved for defined intra-network
services and all emergency services.
(iii) Codes in the range 100 – 139 shall be reserved or used for harmonised
services or application common to the various networks while 140-189 shall
be used by operators for innovations
(iv) Codes in the range 190 - 198 were reserved for special services as
designated by UCC.
(v) The 4-digit shortened numbers were reserved for application or information
providers of value-added services based on SMS and MMS for now, and other
services that may later be defined by UCC.
(vi) That the administration of the shortened numbers/short codes provision
shall be done exclusively by UCC.
(vii) Operators shall be charged fees against any short code used to provide or
access paid for services. Any service that is provided using the code “Exempt
from Authorisation fees”, should be delivered free of charge to the end user.
(viii) The 5-digit shortened numbers should be reserved for adoption at a later
date.
(ix) The numbers already defined by the operators for intra-network
services are ‘frozen’ as they are for a maximum period of three years from
the date of pronouncement (2007)of this provision by the Commission, but
all future assignments should be done according to the defined shortened
number provision. These numbers, for example, then included 1100 for
Celtel, 123 for MTN, and 222 for UTL.
Following the introduction of the 4–digit shortened numbers that application
providers could directly access, a corresponding growth in services provided using
shortened numbers was realised.
Uganda Communications Commission Consultation Document, Jan 2012 Page 6

7. Presented below is a graph showing the trend of assignments made for the 4 –digit
and 3 digit shortened numbers in the innovation space (140-189) over the period
2007 – 20101.
Over the period, as shown in the graph, there has been rapid introduction of new
Value added services (VAS) provided by a multitude of application providers using
the various telecom networks available. Network operators on the other hand had a
peak growth in 2007, after which slow growth is observed in the number of
assignments made to network operators in the innovation space. This trend
however may be attributed to re- use of codes for promotional purposes, non
compliance by operators to the revised Short code provision as well as the
perception that USSD codes were not covered by the provision.
An analysis of the existing services provided over various networks shows that there
is a growing range of services and applications with limited systematic organisation
of these services within the ranges / codes over which they are provided.
The area of Value added services continues to be a high potential avenue for
innovation and growth within the telecom sector for both application providers and
network operators due to the growing versatility of services that can be availed to
meet ever growing needs of mobile customers.
Cognisant of this fact, requests made by industry stakeholders as well as other
technological developments, the Commission in a bid to enable growth and
harmonisation, enhance compliance and promote delivery of innovative services,
would like to review the existing short code provision.
1
Data extracted from UCC short code assignment database
Uganda Communications Commission Consultation Document, Jan 2012 Page 7

8. 2 The Existing short code provision
The Uganda National Numbering Plan guidelines provide for the use of short codes
as follows:
The codes are categorised as follows:
(i) Emergency Service Codes (110-119,900-999)
(ii) Common Network Codes (120-139) with further specific allocations in
consideration of harmonisation across all networks as shown in the table
below:
(iii) Independent Network Codes (140 -189) for operator innovations
(iv) Special Services Codes (190-198) for UCC assigned special services
(v) Content Codes (6000-8999) for application providers
Uganda Communications Commission Consultation Document, Jan 2012 Page 8

9. 3 ISSUES UNDER CONSULTATION
3.1 Access to codes
The existing provision provides access to three digit codes for only network
operators in the Independent Network codes range for provision of innovative
services. Application providers have access to four digit codes in the Content Codes
range and in cases where they require a three digit code for provision of services;
they have to acquire this code through the respective network operator.
Information from industry players indicates a large demand for the three digit codes
arising mainly from the need to deploy Unstructured Supplementary Services Data
(USSD) applications to provide interactive services.
The market is currently moving towards more interactive, real time services, which
can best be offered over USSD.
The challenges that have been raised related to access to three digit codes by
application providers include;
 Acquisition of a uniform code across networks: In most cases, it is actually
impossible to acquire a uniform code across networks, as the codes have
often been otherwise utilised by the operators.
 The cost implication of acquiring a code across all networks: Due to the fact
that they must approach and acquire the code independently from each
operator, the cost of deploying a single service on multiple networks is
multiplied by the number of networks compared to when a 4 digit code is
used.
These issues as such form a barrier to service provision on the side of application
providers.
On the other hand, network operators are reluctant to deal with multiple requests
and subsequent network connections from application providers due to various
reasons e.g. network security may be compromised.
As such, most of them have developed models whereby all application providers
intending to provide services over their network have their content aggregated by a
recommended provider who then provides the connection to the network operator’s
infrastructure.
Uganda Communications Commission Consultation Document, Jan 2012 Page 9

10. 3.2 Categorisation of services offered and Consumer Protection
There is currently a vast range of services offered over telecom networks.
Consumers face difficulty in recalling and using the multiplicity of codes used to
offer the various services as any service may be offered on any code within the
applicable range.
This random usage of codes also exposes consumers to exploitation due to the lack
of knowledge on appropriate tariffs (free, standard SMS or premium rates)
applicable to the different services. Consumers are further exposed to inappropriate
content as well as unsolicited content.
It would thus be desirable to categorise services with respect to content as well as
tariffs so as to mitigate the above challenges.
Uganda Communications Commission Consultation Document, Jan 2012 Page 10

11. 4 Questions and Comments
Provide input to the issues highlighted above with the guidance of the following
questions;
1. Comment on the existing short code standard particularly analysing the
impact of access to codes on your business, today and in light of future
advancements of the technology. Show how it is enabling /limiting and
propose amendments that may address these limitations.
2. In light of the issue on access to codes, given that there is an already existing
pseudo 3 tier structure i.e. (Operator – Aggregator –end user) discuss the
need for any further regulatory intervention in ensuring equitable access to
short codes.
3. In regularising the above said issues (access to codes, categorisation of
services offered and consumer protection) migration of services to different
codes from the ones currently used for the services is an inevitable outcome.
a. Make proposals on how this categorisation may be integrated into the
existing/improved standard with minimal migration effects?
b. Pointing out specific challenges, make proposals of what regulatory
support may be provided to ensure a smooth and successful migration
process.
Uganda Communications Commission Consultation Document, Jan 2012 Page 11