ACCAN submitted on NBN Co’s Consultation Paper 1 nbn 2025 Replacement Module Application (the Paper) as part of NBN Co’s compliance under the economic regulation regime established by the August 2023 Variation of the Special Access Undertaking (SAU).

ACCAN received an Australian Government grant of $2.5 million over two years to represent consumer voices and interests in the development of NBN Co’s expenditure proposals and service standards for Financial Years 2026 – 2029, to ensure they meet the needs of Australian consumers.

Consultation Paper 1 is one of two public-facing papers that NBN Co is seeking feedback on, to better inform their expenditure proposals over the Financial Years 2026 – 2029. The Paper provides a useful and informative overview of NBN’s capital expenditure (capex), operating expenditure (opex), its climate transition and resilience initiatives, as well as its plans to invest further in fibre-optic cables to enable household speeds of above 2 Gbps.

While the Paper marks a positive step forward, the obligations required by the Australian Competition and Consumer Commission (ACCC) for NBN Co to submit a Replacement Module Application (RMA) may require it to provide significantly more detailed and granular information in its second consultation paper, and in discussions with the Regulatory Proposal Forum and the ACCC. ACCAN recommends that NBN Co:

• Provide more granular and disaggregated details on capital and operating expenditure within Consultation Paper 2 and the Regulatory Proposal Forum.
• Tie investment in climate and resilience initiatives to consumer welfare.
• Clearly detail the benefits of >2Gbps services for Australian consumers.
• Develop a medium-term plan to upgrade the Entry Level Plan from 25 Mbps to 50+ Mbps.

Without this information, it is not possible for external observers such as ACCAN to provide effective input. Even though NBN Co’s proposals appear to be plausible and consistent, without granular details at this consultative period of the process, stakeholders will have little ability to inform NBN Co as to how and where it could better prioritise its expenditure, as intended under the SAU.

Therefore, in order to gain better feedback for Consultation Paper 2 and throughout the later stages of the regulatory process more broadly, ACCAN advises NBN Co to provide more granular detail on its expenditure priorities, its climate transition initiatives, and how it can more effectively deliver quality and affordable services to consumers across Australia.

Download: ACCAN Submission to NBN Co Consultation Paper 1526.33 KB

Download: ACCAN Submission to NBN Co Consultation Paper 1252.58 KB