Ok I was wrong, from the overview there: > From 1 July 2019 as a result of new rules from Ofcom, In the UK a customer can request a PAC without having to speak

Ok I was wrong, from the overview there: > From 1 July 2019 as a result of new rules from Ofcom, In the UK a customer can request a PAC without having to speak to their provider by texting PAC to 65075. So it's more recent than I thought (the requirement, the 'donor-led' nature it mentions and ability to do it by text has definitely existed longer at least with willing networks) and UK thing postdating leaving the EU.