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The new code stipulates the account holder, not the device holder, must consent to additional overage fees, which apply per account, not per device. Device holders can only consent to extra fees if the account holder explicitly gives them permission.

While Rogers “appreciates the spirit” of the changes and will implement most of them immediately, including the elimination of device unlocking fees, it said it does not have enough time to update billing systems to fully comply with overage notifications. It asked for an extension until May 31, 2018.

At issue is how it will deal with accounts that include single plans and shared plans. Rogers’ application stated that its systems are not sophisticated enough to accommodate multiple data buckets. It’s upgrading its systems to do so, and building a self-serve system for customers to manage which users can consent to overage fees.

The new rules also require wireless providers to include data top-ups in the $50 data cap and pay-per-use travel packs in the $100 roaming cap. But Rogers’ system treats top-ups and travel packs completely separately from overage. Since it cannot predict how many customers may roam in any given month, it would have to manually monitor all 10 million subscribers to meet this requirement.