Submission to the Communications Authority in Response to the Public Consultation on Renewal of Domestic Pay Television Programme Service Licence 2026

1. The Consumer Council (the Council) is pleased to submit its views to the Communications Authority (CA) on the renewal of the licence of domestic pay television programme service provider Now TV Limited (Now TV).

The Council’s overall views

2. Now TV served around 1.5 million subscribers as of June 2025, according to the information document of the public consultation (Information Document).  Meanwhile, according to the Broadcasting Service Survey 2024, 9.6% of television viewers indicated they had watched pay TV programmes in the past month_[1].  The prevalence of Now TV and its current status as the sole provider of domestic pay television programme services make its licence renewal an important matter of consumer interest_[2].

3. From a consumer interest point of view, the Council opines that when making renewal recommendations, the CA should consider both the regulatory compliance performance of Now TV and its past consumer service performance, and push for improvements through license conditions, codes of practices or otherwise.

4. Between 2019 and 2025, the Council received 670 complaints related to Now TV.  The top nature of complaints were variation or termination of contract (37%), quality of services (33%), price or claim dispute (17%), and sales practices (8%).       

^* The rise in complaints in 2020 can be attributed to wide suspension of football matches globally due to the COVID-19 pandemic and consumers consequently unable to view such content.  Meanwhile, the rise in complaints in 2021 can be attributed to Now TV ceasing to deliver FOX-branded channels, causing consumer dissatisfaction.

^# Such as complaints over repair or maintenance services, quality of goods, expiry date, free gifts, discounted goods or promotion, and installation.

5. In the following parts, the Council puts forward its views and suggestions on consumer-related issues for the CA’s consideration in formulating its renewal recommendations.  

Ceasing to deliver specific content and channels for consumers

6. The Council observes that a recurring concern among consumers is the cessation of programmes and channels by Now TV during the contract period, giving rise to complaints of variation of contract.  Such consumer dissatisfaction was especially noticeable in 2021 when Now TV ceased to deliver FOX-branded channels.  Consumers felt aggrieved as the affected programmes or channels were often the key reasons for subscribing to the services, which are marketed in bundled packages.  In some cases, channels were no longer available within just several months after consumers entered into their subscriptions.

7. Furthermore, consumers currently lack a fair and reasonable means of redress when such service changes occur.  Under the current terms and conditions of Now TV, subscribers remain liable for early termination charges and other termination charges if they wish to end their contracts following the cessation of programmes or channels_[3].  The Council opines that such treatment of consumers in the event of unilateral change by service providers is unfair_[4]. 

8. In Singapore, consumers may cancel their subscription television service within 30 days without incurring early termination charges when the service provider (i) ceases the provision of any material channel, or (ii) ceases to provide or removes 20% or more of the total channels, or (iii) ceases to provide or removes any material sports content in any channel.  Whether a channel or sports content is deemed “material” hinges upon factors including viewership and level of consumer interest in the channel_[5].  The Council opines that this approach can provide greater protection and fairer treatment of consumers in situations of unilateral service changes.

9. In view of this, the Council suggests that the CA should encourage Now TV to maintain stability in its programme and channel line-up and to be transparent about planned or foreseeable changes when promoting or delivering its services.  The CA should also encourage Now TV to offer consumers an easy way to terminate the service contract, without penalty or receive a pro-rata refund for prepaid fees, when such changes take place. 

Bundling of channels   

10. The Council’s complaint cases showed that some consumers were dissatisfied with Now TV’s sales practice of selling its services in bundles, whereby channels they which to access are packaged together with channels they do not require.  The Council also observes that subscription for certain channels, such as channels showing Premier League football, require consumers to subscribe to other service packages as a precondition_[6].  The Council opines that in addition to the obvious disadvantage to consumers of higher costs, such bundling practices expose consumers to the risk of paying for unnecessary services when the specific channel they desire becomes unavailable.      

11. The Council stresses that during the previous licence renewal public consultation exercise in 2013, the public had already expressed concern over Now TV ceasing to provide channels on an à la carte basis and consumers being forced to pay a high price for a package of channels they would not otherwise acquire_[7].  It seems to the Council that the public’s concerns have yet to be satisfactorily addressed.  The Council suggests that the CA may encourage Now TV to provide an option for consumers to subscribe on a à la carte basis for every channel it offers.

Service package differentfrom what had been communicated    

12. The Council also received complaints on Now TV from consumers indicating that the service package they received did not align with the information provided by salespersons.  These discrepancies led to complaints about contract variation and concerns regarding sales practice.  Such discrepancies included differences in monthly fee, channels included, and promotional supplementary services such as Netflix. 

13. In light of the above, the Council suggests that the CA should urge Now TV to improve its transparency and provide detailed information to consumers before contract signing, such as contract duration, price, channels included, as well as renewal and termination policy.  The Council notes that in the European Union, providers of public available electronic communication services including cable television networks are required to provide consumers with a one-page contract summary on a durable medium prior to the conclusion of the contract.  The contract summary includes the price and main characteristics of service provided, amongst other required items_[8].

Renewal and termination of services    

14. There were also complaint cases regarding the automatic renewal of Now TV services without adequate reminders or guidance on how to opt out.  Under Now TV’s terms and conditions, upon the expiry of a current subscription, Now TV would continue to provide and charge for services on a month-to-month basis if (i) Now TV is unable to contact consumers, or (ii) consumers do not contact them, or (iii) consumers are undecided over whether to renew the contract_[9].  The Council opines that this arrangement places consumers at a disadvantage, especially if consumers do not recall that their contract is nearing expiry. 

15. To ensure consumers have ample time and opportunity to consider whether to renew their services, the Council suggests that the CA should urge Now TV to provide reminders to consumers at a reasonable time before their subscription ends.  The Council suggests that this may be set as at least 30 days prior to expiry, having regard to the Code of Practice for Telecommunications Service Contracts adopted voluntarily by the telecommunications services industry, which mentions that contracts with a fixed term shall oblige service providers to notify customers of expiry of the contract no more than 60 days and no less than 30 days prior to expiry_[10].  The Council also suggests that such reminders provided to consumers should include information on whether the subscription is subject to automatic renewal and how to terminate services.  The reminder should also be delivered through means that are effective and likely to draw consumers’ attention.        

16. Moreover, the Council received complaints on Now TV where consumers encountered obstacles and delays when requesting termination, including being treated indifferently and impolitely, and delayed handling of termination forms.  In light of this, the Council suggests that the CA should require Now TV to provide direct and convenient means of termination, including both online and offline options.  Now TV should also provide consumers with confirmation upon receiving their termination request.    

Service disruption  

17. The Council notes that Now TV had suffered a service outage lasting at least several days in 2025.  Apart from the CA receiving complaints on this matter_[11], the Council also received numerous related complaints, which contributed to the sharp increase in complaints over service quality in 2025.  The Council opines that the CA should stress to Now TV the need to improve service reliability and ensure that Now TV has adequate equipment and staff to minimise the occurrence or duration of future service outages.  Moreover, Now TV should inform consumers about such service disruption within a certain reasonable timeframe.

18. The Council also received complaints where consumers demanded compensation for service disruptions, or expressed dissatisfaction with the proposed compensation by Now TV.  Now TV currently states in its terms and conditions that it has no responsibility to pay consumers any compensation for any loss resulting from service interruption or suspension_[12].  Despite so, the Council notes that some complainants had been offered compensation in the form of “Now Dollars”, a kind of membership points.  Yet complainants preferred monetary compensation.  

19. The Council notes that in Belgium, since November 2024, end-users of television services who suffered a full interruption of at least 8 consecutive hours are entitled to compensation from the operator.  The compensation is at least €1 for the first 8 hours, and then increased to an additional €1.5 per day of continued interruption after 24 hours.  Alternatively, end-users are entitled to at least one-thirtieth of the monthly subscription fee if that exceeds the value of the aforementioned compensation.  While operators can provide compensation in-kind, for example free movies, consumers can still choose financial compensation instead_[13].  The Council suggests that the CA make reference to compensation practices in other jurisdictions, and request Now TV to come up with arrangements that ensure consumers are compensated fairly for service disruptions. 

Accommodating elderly consumers  

20. The Council has come across complaints on Now TV involving elderly consumers being sold unsuitable or costly services, or being charged for printed bill fees.  The Council observes that under the Code of Practice for Telecommunications Service Contracts, for contracts involving customers aged 65 or above, the service provider is encouraged to make quality control calls to them to ascertain their confirmation before conclusion of the contract, or make available dedicated customer support channels or relevant measures to facilitate them to enquire about the contractual features or services subscribed_[14].  The Council also observes that the Guideline on Elderly-friendly Banking Services recently released by The Hong Kong Association of Banks in January 2026 requires banks to waive postage and printing fees for paper monthly statements for elderly customers_[15].

21. The Council suggests that the CA can urge Now TV to attend to the needs of elderly consumers and make reference to the aforementioned elderly-friendly measures adopted by the local telecommunications service sector and banking sector.  In promoting services to elderly consumers, the frontline staff and salesperson of Now TV should receive dedicated training, exercise extra caution, and ascertain such consumers’ confirmation of terms and services before concluding contracts.  In providing customer services to them, Now TV should also exercise greater flexibility to accommodate their genuine needs, such as waiving charges for printed bill fees and providing printed documents with larger font sizes. 

Programme variety

22. The Council notes that according to the Broadcasting Service Survey 2024, only 55% of pay TV viewers expressed satisfaction with programme variety, with 30% considering it average and 9% of viewers expressing outright dissatisfaction.  Amongst those expressing dissatisfaction, 55% stated their dissatisfaction was related to lack of attractive content, followed by 52% saying it was related to lack of programmes with new ideas and different approaches, and 51% saying it was related to a lack of exclusive content.  The Council opines that the CA may urge Now TV to take note of the consumer opinions and to commit to further diversify its programme offering.  The CA should also closely monitor the performance of Now TV in this area.

Conclusion

23. The Council is of the view that the renewal of licence of Now TV offers an opportunity for the CA to encourage better service standards. 

24. The Council appreciates that Now TV has voluntarily issued a Code of Practice on Customer Service (Code).  The Council opines that regular assessment of the Code and timely revision based on consumer feedback can help ensure its relevance and effectiveness_[16]. 

25. As outlined above, the Council identified several potential areas of improvement.  The Council calls upon the CA to take into consideration the above comments in making recommendations on the renewal of the licence of Now TV, so as to enhance consumer protection.