Marketing in the eBill: an ambush?

We’ve established the value of the marketing real estate offered within a push eBill package. The cover email, the index page, additional tabs; there are many opportunities for marketers to reach an essentially captive audience.

Everyone looks at their bills, right?

Therein lies the potential snag. Your customers read their eBill because it’s their statement or invoice and they need to take action based on the content. Now we’re adding marketing and sales information and suddenly the package isn’t just a statement, it’s also a brochure, or a billboard or a mini-website.

Is this an ambush?
Paper bill delivery provides many ways of sneaking a bit of marketing into the customer’s view. Envelope messages, statement ‘stuffers’, on-bill messages - the recipient can choose to read the marketing material or ignore it.

Marketing within the eBill is a kind of digital statement stuffer, and the recipient can either pay attention to it or decide not to.

Choosing not to click is really the same as throwing the glossy printed brochure into the recycle bin.

Then I guess the question is: can your customers currently opt out of paper bill marketing? Do you provide the option to receive a clean envelope with no marketing, so only the statement is enclosed?

Legal implication
Consumer reaction aside, there are compliance issues in regions where consumer rights are protected and where direct marketing is regulated either by law or by an industry Code of Conduct.

The ability for a consumer to Opt Out of direct marketing is entrenched in many societies. What is not clear, is whether placing marketing messages inside an operational communication like a bill is still considered direct marketing.

If it is, then the consumer has the right to Opt Out of receiving those marketing messages, meaning the Biller would have to offer a vanilla bill without any marketing flavour.

Early Days
I posed this question to a direct marketing-savvy professional whose opinion I respect, and her view was that the Bill is a natural vehicle for the marketing side of the business to leverage. In her business, as in many industries, sending a regular bill to a customer is a legislated requirement and therefore part of the cost of service. So companies must take the opportunity to maximise this customer touch point with either operational or marketing messages.

I expect, in my geography of expertise (South Africa), we will only begin to see opinion on this once the Consumer Protection Act comes into full force in October 2010.

I’d be interested to get comment from other regions as to whether there is specific legislation or codes around marketing in the eBill and if any case law exists on this niche topic.

AlisonTreadaway
Managing Director
Striata South Africa
www.striata.com