I think Orange should be dragged up before the regulators and asked to explain whether and why they are leaving it until the very last minute
Its perfectly clear to me! There is nothing that the networks love more than these "bill-shock" stories! As long as they can get these within the law, they will quite happily not enforce this.
By the way, I wonder how many people realise they can put voluntary credit limits on their accounts. I have one of my contract SIM's set at 10 pounds! Basically, I never want it to go over the inclusive allowance.